Authors: Mike Magner
Therefore, I expect this to be an informal review. If you prefer a different approach, I ask that you give me your “informal” comments so that I can go ahead and address them in the document, then if you choose to send formal signed comments for the record, the time delay will not affect the release date. I need to receive your “informal” comments by June 23, 1997, preferably by phone. If I haven't heard from you by then, I'll call you Tuesday, June 24. Ideally, I'd like to discuss your comments over the phone so that I can make the changes to the document at that time to quicken the process.
22
The request for a review ended up with Katherine Landman at the Naval Facilities Engineering Command, Atlantic Division (
LANTDIV
), who sent a July 21, 1997, memo to David McConaughy at the Navy Environmental Health Center, forwarding a copy of the
ATSDR
's draft
PHA
along with eight pages of “informal” comments that Landman had already sent to the health agency. The draft
PHA
, Landman said in the memo, had been provided by Carole Hossum of the
ATSDR
“for an âinformal' review prior to formal issuance of the report.” Landman added, “I have discussed these comments with Ms. Hossum on the phone, and she has indicated to me that substantial changes will be made to the document regarding most issues that I mentioned in my comments. . . . Because Ms. Hossum requested only an informal review from a limited list of people, please provide any comments or concerns you may have about this document to me (informally), and I will forward to
ATSDR
with additional specific comments of my own that I am still generating.”
23
In her eight pages of comments on the
ATSDR
's draft report, Landman provided a list of documents from Camp Lejeune's Superfund cleanup files. This was in response to the health agency's request for “updated records for particular sites” on the base. None of the listed documents dealt with the benzene contamination in the Hadnot Point water system. Most of the remaining comments focused on all the efforts Camp Lejeune was making to ensure that contamination never got into the base drinking water again.
24
On the day the
PHA
was released, August 4, 1997, the director of the
ATSDR
's Division of Health Assessment and Consultation, Robert C. Williams, sent a letter to the commanding general and the brigadier general at Camp Lejeune to notify them about the report. “The data and information in the U.S. Marine Corps Camp Lejeune Military Reservation Public Health Assessment have been evaluated, and
ATSDR
has placed the U.S. Marine Corps
Camp Lejeune Military Reservation in the category of no apparent public health hazard.”
25
Christopher Portier, who took over as director of the
ATSDR
in August 2010 and left in May 2013, admitted in an interview after his departure that agency researchers could have been more aggressive about tracking down all the contaminants, including benzene, when they started investigating Lejeune's water problems in the early 1990s. He also admitted the Marine Corps wasn't exactly screaming that health officials had overlooked significant fuel leaks from underground storage tanks and pipelines in the Hadnot Point area.
26
“My sense of it was that in 1991 we were called in to investigate the âPerc' [perchloroethylene] contamination coming onto the base from ABC Cleaners, and did a fairly good job of that,” Portier said. “But
ATSDR
did not recognize the magnitude of the contamination that was coming from a different direction, that's from the underground storage tanks, until later on. It is unfortunate that the team that was looking at it early on dismissed the benzene readings that were right in front of their eyes and did not further investigate it because that might have cut the amount of time spent on this particular issue.” But, Portier added, “there were difficulties getting some of the records over the years that made it hard for us to do our work.”
27
The
ATSDR
's acknowledgment that its 1997 report on Camp Lejeune was badly flawed was met with a mixture of relief and concern from both Jerry Ensminger and Mike Partain. Ensminger ridiculed the
ATSDR
's statement that it was still trying to determine whether benzene had made it from a contaminated well into the base drinking water. “We have analytical results from samples taken on 6 July 1984 which show high contamination levels of benzene in well HP-602,” Ensminger said in an e-mail to the
ATSDR
's deputy director, Thomas Sinks. “By the
DON
/
USMC
's own
admission, this well wasn't removed from service until 30 November 1984. We do know there was benzene contamination in that well when it was still active, [so] why is
ATSDR
âmuddying' the facts here?” Partain noted in an e-mail to Sinks that a test done in December 1985 on finished water from the Hadnot Point water treatment plant showed benzene present in the drinking water at 38 parts per billion.
28
Still, Partain applauded the agency in his note to Sinks for taking a major step toward acknowledgment of the damage done by Lejeune's contamination. “Withdrawing the
PHA
as a viable document from your agency's database demonstrates a sincere effort to involve the community and not just accept the statements and assertions of the polluters as fact,” Partain said. Ensminger, as usual, was more emphatic than his partner in describing his reaction to the
ATSDR
's removal of the 1997 report from its website. “We are in Day 99 of change, and by God we're starting to see it,” Ensminger told the Associated Press for a story about the agency's action, roughly a hundred days after Obama had promised a greater emphasis on scientific integrity in his administration.
29
The new optimism that Partain and Ensminger shared was quickly shattered by the June 13, 2009, announcement from the National Academies of Sciences that a lengthy study by a committee of the National Research Council had found no conclusive evidence that illnesses could be directly connected to contaminated drinking water at Camp Lejeune.
30
“It cannot be determined reliably whether diseases and disorders experienced by former residents and workers at Camp Lejeune are associated with their exposure to contaminants in the water supply because of data shortcomings and methodological limitations, and these limitations cannot be overcome with additional
study,” reported the
NRC
committee, which had been funded by the Navy under a mandate from Congress. “Thus, the committee concludes that there is no scientific justification for the Navy and Marine Corps to wait for the results of additional health studies before making decisions about how to follow up on the evident solvent exposures on the base and their possible health consequences. The services should undertake the assessments they deem appropriate to determine how to respond in light of available information.”
The committee's 317-page report reviewed epidemiologic studies of solvents and their effects, studies of other communities that had had contaminated water supplies, laboratory research on
TCE
and
PCE
, and the studies that had been done so far on the population at Camp Lejeune. In each category, the committee had concluded that there was “inadequate/insufficient evidence to determine whether an association exists” between exposure to the chemicals and adverse health effects.
The committee had also evaluated whether further health studies of former Camp Lejeune residents, as recommended in June 2008 by
ATSDR
epidemiologist Frank Bove, would be useful in determining the effects of the water contamination at the base. “After reviewing the study plans and feasibility assessments, the committee concluded that most questions about whether exposures at Camp Lejeune resulted in adverse health effects cannot be answered definitively with further scientific study,” the panel reported.
There are two main reasons for this. First, it is not possible to reliably estimate the historical exposures experienced by people at the base. Second, it will be difficult to detect any increases in the rate of diseases or disorders in the study population. Most of the health effects of concern are relatively rare, which means that very
large numbers of people are needed to detect increased cases. Although the total number of people who have lived at Camp Lejeune while the Tarawa Terrace and Hadnot Point water supplies were contaminated is sizeable, the population is still unlikely to be large enough to detect effects, other than common diseases or disorders, of concern.
The committee also had a message for some of those who had spoken at the three public hearings on Camp Lejeune's contamination. “Many of the people who addressed the committee have suffered from serious diseases or have family members or friends who have suffered,” the panel's report said. It went on:
The committee was moved by the testimonies it heard and understands that some may have been looking for the committee to make a judgment on their particular case. However, science does not allow the committee to determine the cause of a specific case of disease. This may be hard to understand. Why would scientific experts not be able to determine whether a child's birth defect or a parent's cancer diagnosis was due to a chemical exposure? Unfortunately, for diseases that have multiple causes and that develop over a long period of time, it is generally impossible to establish definitively the cause in individual cases.
To sum it all up, the committee's chairman, David Savitz of the Mount Sinai School of Medicine, issued a statement in a press release sent out by the National Research Council when its report was released. “Even with scientific advances, the complex nature of the Camp Lejeune contamination and the limited data on the concentrations in water supplies allow for only crude estimates of exposure,” Savitz said. “Therefore, the committee could not determine reliably whether diseases and disorders experienced by former residents
and workers at Camp Lejeune are associated with their exposure to the contaminated water supply.”
31
Almost immediately after the report came out, a political and scientific firestorm erupted.
“The
NAS
study released Saturday is simply a review of previous scientific literature on hydrocarbon solvents, reports on Camp Lejeune water contamination, and published epidemiologic and toxicological studies,” said Democratic senator Kay Hagan of North Carolina. Hagan condemned the study on several grounds:
It failed to take into account the conclusions of previous epidemiological studies that found an association between volatile organic compounds (
VOC
s) exposures and childhood leukemia, and presents some direct contradictions to the
EPA
's maximum containment levels of
VOC
s in drinking water. Moreover, the
NAS
study barely mentioned benzene and vinyl chloride and severely downplays the established links between adverse health effects and exposure to
VOC
s that were present in the water at Camp Lejeune. For these reasons, I cannot stand behind the validity of the
NAS
study.
32
“It's clear that the water at Camp Lejeune was contaminated by a number of hazardous chemicals at unsafe levels,” said her colleague in the Senate from North Carolina, Republican Richard Burr. “I am deeply concerned about the conclusions in the report from the National Academy of Sciences. This latest report still raises more questions than it answers.”
33
“We are disappointed and dismayed at the report,” said five scientists who had worked closely with victims of the contamination: Ann Aschengrau, Richard Clapp, and David Ozonoff of the Boston University School of Public Health; Daniel Wartenberg of the Robert Wood Johnson Medical School; and Sandra Steingraber of
Ithaca College. In a June 17, 2009, statement released to the media, the scientists said the report “reached puzzling and in some cases erroneous conclusions. . . . The
NRC
doubts that âdefinitive' answers can come from any study, but this sets the bar too highâno one study can provide definitive answers, and all studies must be considered in the light of other scientific evidence. From our experience in other settings, we believe that useful studies of the Camp Lejeune population are possible and furthermore that the Marines and their families deserve our government's best efforts to carry them out.”
34