In the 1980's, the U. S. Congress created the Agency for Toxic Substances and Disease Registry (ATSDR) to perform human health and environmental risk assessments at National Priority Listed (NPL) (aka: "Super Fund") contamination sites in the United States. The ATSDR was also tasked with creating toxilogical profiles for the chemicals found at these sites and else where in our environment and to create a registry for human exposures to chemicals at these NPL sites.
Camp Lejeune was officially placed on the NPL in 1989 which automatically required an investigation/study by the ATSDR as to whether or not humans were exposed to the chemicals at this site. They were also tasked with assessing the health risks associated with those exposures. The report of the ATSDR's investigations/studies at these NPL sites are referred to as Public Health Assessments (PHA's). This posting will cover in detail the PHA that the ATSDR published in August 1997 for Marine Corps Base, Camp Lejeune, N. C. (MCB, CLNC).
The ATSDR first appeared at the Camp Lejeune NPL site in 1991 to execute its Congressionally mandated mission. From the beginning, it is quite apparent that the United States Marine Corps/Department of the Navy representatives at CLNC, Naval Facilities Engineering Command, Norfolk, Va. (NAVFACENGCOM), and the Navy Environmental Health Center (NEHC) did not appreciate the ATSDR looking around their "back yard!" There are repeated requests by ATSDR for information/data concerning the contamination sites/exposures at CLNC. There are letters complaining that the points of contact at CLNC were "uncooperative" in providing the data which they needed and that when they did provide data, there was no documentation to support it! From looking at these historical documents, one can ascertain that the USMC/DoN were engaged in a campaign to stall, delay, confuse, and intimidate the staff from the ATSDR. Evidently, these tactics had the desired effect. I have reviewed most of the different draft PHA's which the ATSDR had written for MCB, CLNC and the "evolution" of the language the ATSDR used in describing the contamination at CLNC is testimony in itself that the USMC/DoN's stategy was working. When the final PHA was issued in August of 1997, it was full of inaccuracies and assumptions which favored most of what the USMC/DoN wanted to see, no/very little impact on human health. I must at this point give the ATSDR some credit for the firm stance they took on fetal exposures, however, the exposures to the majority of people, Marines, Sailors, their dependents, and the civilian employees had been effectively minimized to give these populations a false sense of security. In other words, no harm would come to them because of their exposures to Volatile Organic Chemicals (VOC's) in Camp Lejeune's drinking water.
Note: It has also been determined that USMC/DoN provided the ATSDR with erroneous water system data (multiple times) which is still reflected in this document.
Let's take a look at the VOC Exposure Estimates in Appendix E-1 of the August 1997 PHA for Camp Lejeune. There are several factors which the ATSDR used in these estimates which are not only questionable today, they were questionable when this document was initially written!
1.) Why was the exposure factor based on 4 out of 7 days per week? Where in the hell did these people think we went for the other 3 days of the week?
2.) The daily ingestion rate was based on 2 litres per person per day? California's current ingestion rate for people living with contaminated water is 7 plus litres per day. 2 litres per day? Did these people think we were rats? Marines had physical training (PT) at least 3 times per week, many units had PT every morning, after PT everyone showered prior to going to the messhall for the morning meal. Not to mention the fact that most of the work spaces aboard Camp Lejeune during that period of time were not air conditioned. During the Spring, Summer, and early Fall months we drank water constantly just to keep hydrated and then everyone would require another shower after normal working hours. 2 litres per day? Please!!!
3.) Once you skew these first 2 catagories, it greatly reduces the estimated dose which greatly reduces the cancer slope factor which in turn ultimately reduces the adult cancer risks!
Now, I hate to sound like a conspiracy theorist but it most certainly appears to me that someone was purposely manipulating numbers which would reduce the risk!
It is also a known fact that the ATSDR personnel who were working on the CLNC, PHA were billeted and fed at the Camp Lejeune officers club during each and every visit they made to CLNC. Is this how an agency tasked with investigating/studying exposures at NPL sites should conduct itself? Does the ATSDR accept hotel, food, drink, and transportation accommodations from private industry NPL sites? I can answer that question, hell no! The ATSDR compromised their independence and impartiality right from the beginning at Camp Lejeune. They were provided VIP quarters at the officer's club, they were provided transportation from the USMC, and they were socializing with representatives of the polluter over meals and drinks at the "O" club in the evenings. The representatives of the ATSDR were the Mules and the USMC/DoN representatives were giving them the old "carrot/stick" treatment!
Take a look at Table 3. Potential Health Effects for VOC Exposures in the CLNC, PHA. You will note that without exception the adult cancer risk is a definitive "No", not "unlikely", not "unknown", it is "No!" I then want you to read the text on the page which follows Table 3, titled "Cancerous Effects", there are numerous statements in their own document that counter their conclusions in their Table. For example;
1.) "not enough scientific information on humans is available to rule out the possibility of cancerous health effects from low dose exposure to VOC's." WHAT???!!! Table 3 said "No" to cancerous effects in adult exposures!
2. "A few epidemiologic studies have suggested that exposure to VOC's may be associated with leukemia, non-hodgkins lymphoma, and bladder and kidney cancer (39, 40, 41, 42). The exposure doses in these studies were similar to or slightly higher than what was estimated at Camp Lejeune." Why does Table 3 say "No"???!!!
3.) "Because the results of the epidemiologic studies suggest a possibility of cancer from exposure to VOC's at low doses, more studies are needed to adequately address the issue of human cancer associated with low-dose VOC exposure." The ATSDR then goes on to say in their conclusions that no further studies are required for adults exposed at Camp Lejeune!!! Is it just me or do you also feel like we are in the "Twilight Zone?"
I have included Table 3 and the subsequent paragraphs from the PHA for all to see. I found it rather interesting that the Appendices for this document are not included with the PHA on the ATSDR's web-site. If anyone would want to see these appendices on how the ATSDR came up with their conclusions, you must request a "hard copy" from them! How convenient! Here is the link to Appendix E-1 VOC Exposure Estimates
Table 3. Potential Health Effects for VOC Exposures Water System Exposed Population Exposure Time Frame Exposure Activity Drinking Water Contaminant Estimated Exposure Dose
(mg/kg/day) Potential Health Effects
Chemical Maximum Concentration (ppb) Noncancer Effects Cancer Risk Increase†
Hadnot Point Base residents
(Adults, children, and fetuses) Past
1940s-1982 People in the Hospital Point housing complex and other buildings supplied by the Hadnot Point Drinking Water System ingesting, inhaling, and having dermal contact with contaminated drinking water TCE 1400 Adult 1.7E-03 Not Likely, No
Child 3.7E-03 Unknown Unknown
DCE 407 Adult 4.9E-04 Not Likely, No
Child 1.1E-03 Not Likely Unknown
Methylene Chloride 54 Adult 6.6E-05 Not Likely, No
Child 1.4E-04 Not Likely Unknown
Vinyl Chloride 3 J Adult 3.6E-06 Not Likely, No
Child 8.1E-06 Not Likely Unknown
Tarawa Terrace Base residents (Adults, children, and fetuses) Past
unknown 19541982 People in the Tarawa Terrace housing complexes ingesting, inhaling, and having dermal contact with contaminated drinking water supplied by Tarawa Terrace Drinking Water System TCE 8 Adult 9.8E-06 Not Likely, No
Child 2.2E-05 Not Likely Unknown
DCE 12 Adult 1.5E-05 Not Likely, No
Child 3.2E-05 Not Likely Unknown
PCE 215 Adult 2.6E-04 Not Likely, No
Child 5.8E-04 Unknown Unknown
Holcomb Blvd Base residents and workers
(Adults, children, and fetuses) Past
known January 27 February 7, 1985 People in the Paradise Point, Watkins Village, Berkeley Manor, Midway Park housing complexes, and other buildings supplied by the Holcomb Boulevard Drinking Water System ingesting, inhaling, and having dermal contact with contaminated drinking water TCE 1,148 Adult 3.3E-05 Not Likely, No
Child 7.2E-05 Unknown Not Likely
DCE 407 Adult 1.2E-05 Not Likely, No
Child 2.5E-05 Not Likely Not Likely
† - Increased cancer risk is based on > 5.5 x 10-5.
J - Estimated value
NOTE: Dose calculations and cancer risk estimates are included in Appendix F-2.
The Probable Health Effects does NOT include those for fetuses, which would be unknown.
Typically, ATSDR uses human epidemiologic and occupational studies when evaluating the likelihood of cancerous effects or cancer risk. However, too few epidemiologic studies have been carried out on low-level exposure to VOCs to make sound cancer estimates. Therefore, we decided to base our assessment of cancer risk from exposure to VOCs at MCB Camp Lejeune on data from animal studies. The International Agency for Research in Cancer (IARC) classifies TCE and PCE as "probably carcinogenic to humans" based on "sufficient" evidence of carcinogenicity in animals and "limited" evidence in humans (38). The animal studies evaluated the cancer effects from known exposure to VOCs. On the basis of these animal studies, mathematical formulas were derived using factors to convert animal data into values relevant to humans.
Using cancer risk estimates, ATSDR determined that cancerous health effects are unlikely in adults who were exposed to VOCs in drinking water at MCB Camp Lejeune (Appendix E-1). Although cancer is not expected to occur, not enough scientific information on humans is available to rule out the possibility of cancerous health effects from low-dose exposure to VOCs. A few epidemiologic studies have suggested that exposure to VOCs may be associated with leukemia, non-Hodgkins lymphoma, and bladder and kidney cancer (39, 40, 41, 42). The exposure doses in these studies were similar to or slightly higher than what was estimated for people at MCB Camp Lejeune. However, there are too few studies to see any definite pattern of cancers related to VOC exposure. In addition, these studies are further limited methodologically because of the difficulty of verifying and quantifying people's exposure to VOCs. Because the results of the epidemiologic studies suggest a possibility of cancer from exposure to VOCs at low doses, more studies are needed to adequately address the issue of human cancer associated with low-dose VOC exposure.
Health Outcome Data
At this time, ATSDR is not planning a follow-up cancer statistics evaluation of adults at MCB Camp Lejeune for the following reasons. A simple review of cancer statistics from the North Carolina cancer registry would not be useful because cancer registries contain cancer cases diagnosed each month for a specific county. When exposures occur, generally all residents of the county are not equally affected. Instead, the people exposed would be a smaller, localized group such as the small group of residents at Tarawa Terrace, MCB Camp Lejeune. Therefore, evidence of higher cancer rates in groups this small may be hidden within the rates of cancer for the entire county.
In addition, latency for most types of cancer is between 10 and 20 years. This creates two problems. First, those exposed to potential VOC carcinogens in the 19821985 time frame, would just now be beginning to be diagnosed with cancer. Secondly, the average stay of residents at MCB Camp Lejeune at that time was 3 years, and most of the exposed individuals who develop cancer are likely to have moved before they are diagnosed. Hence, most of the cancer cases that might have occurred among exposed individuals would not be recorded in the North Carolina cancer registry as occurring to MCB Camp Lejeune residents.
The potential effects of VOC exposure on children have been evaluated only in Woburn, Massachusetts, where a cluster of childhood leukemia cases has been investigated in several different studies. The Woburn studies suggested an association between childhood leukemia and access to VOC-contaminated drinking water (42, 43, 44). This association was quite strong in children who were exposed to the largest quantities of VOCs in utero (43). In addition, cancer rates declined to expected levels about 8 years after the contaminated wells were closed, which is a reasonable latency period for childhood cancer. The contaminant levels in the Woburn wells were TCE, 267 ppb; PCE, 21 ppb; chloroform, 12 ppb; and other VOCs. The wells were used 59% of the time, and water was blended with water from six other municipal wells, thus lowering the actual concentrations of VOCs people would be drinking at their taps. The risk of childhood leukemia associated with VOC-contaminated drinking water in Woburn was impossible to estimate precisely because the overall number of childhood leukemia cases in Woburn was small, the number of years during which Woburn water was contaminated was not known, and what VOC concentrations were present in tap water was not known. In addition, some associations between chemical exposure and disease arise by coincidence. This is why it is necessary to conduct epidemiologic studies in several different populations to establish a definitive link between exposure and disease. Nevertheless, the findings at Woburn raise concerns about potential childhood cancer risks associated with VOC exposure in utero. Therefore, we recommend that, if feasible, ATSDR conduct a study of cancer in children potentially exposed to VOCs in utero while their parents resided at Camp Lejeune.
Adverse Birth Outcomes
Women may experience adverse pregnancy outcomes from exposure to toxic substances even when their own health is not threatened, because fetuses are potentially more sensitive to the effects of VOCs (45, 46). Several epidemiologic studies suggested the possibility that pregnant women exposed to VOCs (at levels similar to those detected at MCB Camp Lejeune) may have an increased risk of adverse pregnancy outcomes. The outcomes include birth defects such as heart malformations, neural tube defects, oral clefts, low birthweight, and increased fetal death (45, 46-51). Some of these studies have significant limitations, including questions about whether all of the study population was exposed, how long exposure took place, and the exact concentrations of VOCs to which these mothers were exposed. Due to these limitations, more studies are needed to better evaluate the relationship between VOC exposure and adverse pregnancy outcomes.
To help address the issue about pregnancy outcomes, ATSDR began a study at Camp Lejeune in 1995. In an interim report released in 1997, ATSDR identified approximately 6000 infants whose mothers resided in VOC-exposed housing areas while pregnant (52, 53). A statistically significant decrease in mean birthweight and a statistically significant increase in the condition small for gestational age was observed in male infants born to mothers whose housing was supplied with water from Hadnot Point. Birthweight in this group was compared with birthweight of infants of women living in other officers' housing. No differences in mean birthweight or the condition small for gestational age were noted in most residents receiving water from Tarawa Terrace compared with residents of other housing areas. However, in Tarawa Terrace residents, the children of mothers who were 35 years of age or older and the children of mothers who had previously had a fetal loss were more likely to have been born small for gestational age. Infants whose mothers were very briefly exposed to VOCs from the Holcomb Boulevard system were not more likely to have lower mean birthweight or to be born small for gestational age.
Summary and Follow-up
Human exposure to TCE, PCE, and 1,2-DCE in drinking water systems at MCB Camp Lejeune has been documented over a period of 34 months, but likely occurred for a longer period of time perhaps as long as 30 years. Included in the population that used this water were approximately 6000 residents in base family housing (52, 53). This population consisted of a large proportion of young married women. Even though adverse health effects are not expected in adults, concern was raised about potential toxic effects on developing fetuses.
As discussed previously, it is difficult to draw conclusions from a single epidemiologic study, and most of the other epidemiologic studies completed to date have been so different in study design that their results cannot be adequately compared. Also, finding associations in some subgroups but not others is plausible, but was not expected. Research conducted in other groups of infants exposed to these chemicals in utero will be necessary before firm conclusions about the effects of low-level VOC exposure on birthweight can be drawn. ATSDR is currently conducting another study of TCE in drinking water and birthweight as part of its National Exposure Registry activities. The Exposure Registry study may confirm or refute some of these observations. A future report based on the Camp Lejeune birth data will examine the potential association between VOC exposure and preterm delivery and late fetal death. Birth defects will be studied only briefly because the data are too limited for an adequate evaluation.
Another potential effect of fetal exposure to VOCs is childhood cancer. Information about the potential for this effect is limited, but provocative. Therefore, ATSDR recommends a study of cancer in children who were exposed to VOCs at MCB Camp Lejeune while in utero.
Conclusions and Public Health Action Plan
for VOC Exposure (Tap Water)
Before 1986, people drinking and showering with water from the Tarawa Terrace, Hadnot Point, and the Holcomb Boulevard water distribution systems on base were exposed to volatile organic compounds (VOCs). There is information documenting drinking water contamination in the Tarawa Terrace and Hadnot Point water systems from 1982 until 1985, although contamination could have been present longer. Contamination in the Holcomb Boulevard system was present only for two weeks, January 27 February 7, 1985. At the estimated exposure levels, we do not expect cancerous or noncancerous health effects in adults. Even though ATSDR determined that cancerous health effects are unlikely in children, not enough scientific information is available to rule out the possibility of cancerous health effects from low-dose exposure to VOCs such as those at MCB Camp Lejeune. Additionally, fetuses are potentially more sensitive than children to VOCs. Previous studies have suggested associations between childhood cancer, low birthweight, late fetal death, and fetal exposure to VOCs.
ATSDR's Health Study suggests that a statistically significant decrease in mean birthweight and a statistically significant increase in the condition small for gestational age was observed in male infants born to mothers whose housing was supplied with water from Hadnot Point. A copy of the health study can be obtained at the Onslow County Library, Jacksonville, NC, or from ATSDR.
The reason for this posting is to show you, the affected community, the shoddy, and yes, skewed work product that was produced by a Federal agency which was created to protect public health. If you find this Camp Lejeune, Public Health Assessment as outrageous as I do, write to the ATSDR Camp Lejeune web-site and tell them so. There has been resistance by the ATSDR to remove the VOC exposure portion of this document from their web-site even though it is a known fact that it is wrought with errors. I would also encourage each and everyone of you to inform your U. S. Congressional Representatives and Senators of this travesty.
The ATSDR has been in existence for nearly a quarter of a century, they have rarely (if ever) had a conclusive finding in any of their work. There have been several articles written about this agency's ineffectiveness over the years, "Inconclusive By Design" and "ATSDR, Don't Ask, Don't Tell, Don't Pursue", just to name a few. It has become my opinion over the years that perhaps our Federal government would be better served if they did away with the ATSDR. Take the money that is apparently being wasted on the up keep of an ineffective agency and contract future Public Health Assessments and studies to university science/medical departments. I truly believe that if this were to happen, the money that our government would provide to these universities would be utilized to protect public health instead of protecting the special interests of polluters! We have been chasing our tails for far too many years, it is time for a change..........let's make this change happen!