Sixty Years Before Litigation: Reconstructing the Camp Lejeune Drinking-Water Exposure
By Paul E. Rosenfeld, M.S., Ph.D., Principal Environmental Chemist, RoseyFields LLC, Santa Monica, California
The most extreme historical reconstruction problem in modern environmental science
Few exposure scenarios test historical reconstruction methodology as severely as Camp Lejeune, where contaminated drinking water affected a Marine Corps base population from 1953 to 1987, more than three decades before litigation became legally possible. Dr. Paul E. Rosenfeld, M.S., Ph.D. of RoseyFields LLC and coauthors undertook a peer-reviewed cancer risk assessment for this exact exposure window (Rosenfeld et al., 2024).
The contaminants and their sources
Camp Lejeune’s drinking-water wells were contaminated by multiple sources, including a nearby off-base dry cleaner, leaking underground storage tanks, and industrial spills, introducing tetrachloroethylene (PCE), trichloroethylene (TCE), benzene, and vinyl chloride into the base’s water-distribution system for decades before the most contaminated wells were shut down in 1985 (Rosenfeld et al., 2024).
Reconstructing thirty years of water distribution without contemporaneous monitoring
Because Camp Lejeune’s water system was not extensively monitored for these contaminants during the exposure period, ATSDR separately developed a validated historical water-distribution model of the base’s supply wells and treatment plants to estimate monthly contaminant concentrations delivered to specific base housing areas over the full 1953-1987 period, providing the exposure backbone on which quantitative dose and risk calculations can be built (ATSDR, 2013).
Independent epidemiological confirmation of harm
A federally sponsored retrospective cohort mortality study comparing Camp Lejeune personnel to a comparison population at Camp Pendleton found elevated mortality from several cancers, including kidney, and other conditions among the Camp Lejeune cohort, providing population-level epidemiological support independent of any individual plaintiff’s claim (Bove et al., 2014).
The federal legislative response
In August 2022, Congress enacted the Camp Lejeune Justice Act as part of the Honoring our PACT Act, creating a federal cause of action for individuals who lived or worked at Camp Lejeune for at least 30 days between August 1953 and December 1987 and who can show that the contaminated water was at least as likely as not a cause of their subsequent illness.
Why the legislation itself reflects a historical-reconstruction judgment
The Act’s 30-day and multi-decade date-range eligibility criteria are themselves a legislative acknowledgment that meaningful individual exposure documentation from the 1950s through 1980s does not exist for most claimants, making population-level and modeled reconstruction, rather than individual water-sampling records, the practical evidentiary foundation for the entire compensation program.
Applying quantitative cancer risk assessment methodology to the reconstructed exposure
Building on the ATSDR water-distribution modeling, Dr. Rosenfeld and coauthors applied standard EPA cancer risk assessment methodology, combining reconstructed contaminant concentrations, exposure duration, and chemical-specific cancer slope factors, to estimate quantitative lifetime cancer risk for Marines and their families across the 1955-1987 exposure window (Rosenfeld et al., 2024).
The regulatory benchmarks for the key contaminants
TCE and PCE are each currently regulated under the Safe Drinking Water Act with a Maximum Contaminant Level of 5 parts per billion, while EPA’s IRIS program has separately concluded that TCE is carcinogenic to humans by all routes of exposure, providing the toxicological anchors against which the reconstructed historical concentrations at Camp Lejeune are evaluated (US EPA, IRIS).
Why this reconstruction differs from an air-dispersion case
Groundwater and distribution-system contamination behaves very differently from an atmospheric plume: contaminants persist and disperse through pipe networks over years, and well-switching and blending practices at a multi-well base like Camp Lejeune materially affect which housing areas received the most contaminated water in a given month, a modeling challenge distinct from, though methodologically related to, the AERMOD-based air reconstructions used in Dr. Rosenfeld’s other litigation work.
A template for other historical drinking-water contamination claims
The combined water-distribution modeling and quantitative cancer risk assessment framework applied at Camp Lejeune offers a template applicable to other multi-decade drinking-water contamination sites where direct historical sampling data are sparse or nonexistent, a scenario likely to recur as additional legacy military and industrial water-contamination sites come to light.
Why sixty-year-old exposures remain provable
Camp Lejeune demonstrates that even exposures beginning nearly three-quarters of a century ago can be reconstructed with sufficient scientific rigor to support quantitative risk assessment and, ultimately, a federal compensation framework, provided the underlying hydraulic, chemical, and epidemiological building blocks are assembled carefully. RoseyFields.com has additional background on Dr. Rosenfeld’s historical drinking-water exposure reconstruction work.
References
1. Rosenfeld PE, Spaeth KR, McCarthy SJ, et al. Camp Lejeune Marine cancer risk assessment for exposure to contaminated drinking water from 1955 to 1987. Water Air Soil Pollut. 2024;235:124.
2. Agency for Toxic Substances and Disease Registry. Historical Reconstruction of the Water Distribution System Serving Family Housing at US Marine Corps Base Camp Lejeune, North Carolina: Summary. Atlanta, GA: US Department of Health and Human Services; 2013.
3. Bove FJ, Ruckart PZ, Maslia M, Larson TC. Evaluation of mortality among Marines and Navy personnel exposed to contaminated drinking water at USMC Base Camp Lejeune: a retrospective cohort study. Environ Health. 2014;13:10.
4. Honoring our PACT Act of 2022, Pub L No. 117-168, Title VIII, Subtitle B (Camp Lejeune Justice Act of 2022), 136 Stat 1759.
5. US Environmental Protection Agency. Trichloroethylene (TCE); CASRN 79-01-6. Integrated Risk Information System (IRIS). Washington, DC: US EPA.
6. US Environmental Protection Agency. National Primary Drinking Water Regulations: Volatile Organic Chemicals. 40 CFR § 141.61.
7. Agency for Toxic Substances and Disease Registry. Public Health Assessment: Camp Lejeune Water Contamination. Atlanta, GA: US Department of Health and Human Services.
8. National Research Council. Contaminated Water Supplies at Camp Lejeune: Assessing Potential Health Effects. Washington, DC: National Academies Press; 2009.
9. US Environmental Protection Agency. Toxicological Review of Tetrachloroethylene (Perchloroethylene). Integrated Risk Information System (IRIS). Washington, DC: US EPA.
10. US Environmental Protection Agency. Revisions to the Guideline on Air Quality Models. 40 CFR Part 51, Appendix W. Fed Regist. 2017;82(10):5182-5235.
11. Rosenfeld PE. RoseyFields LLC: Historical Drinking-Water Exposure Reconstruction. Santa Monica, CA: RoseyFields LLC; 2026.
12. IARC Working Group on the Evaluation of Carcinogenic Risks to Humans. Trichloroethylene, Tetrachloroethylene, and Some Other Chlorinated Agents. IARC Monographs on the Evaluation of Carcinogenic Risks to Humans, Vol 106. Lyon, France: International Agency for Research on Cancer; 2014.
13. Occupational Safety and Health Administration. Hazardous Waste Operations and Emergency Response. 29 CFR § 1910.120.
14. Austin v Monsanto. Case No. 2:23-cv-272 (D Vt).