Camp Lejeune Suit Master Complaint Filed

Last weekend, the plaintiffs filed a Master Complaint in the Camp Lejeune lawsuits.

The crux of the Master Camp Lejeune Complaint is rooted in the Camp Lejeune Justice Act of 2022.  This document has been created in line with the guidelines established in Case Management Order No. 2, dated September 26, 2023. It’s intended to serve as a foundational reference for individual CLJA actions and works in tandem with the Court-approved Short Form Complaint.

What is a Master Complaint in an MDL or class action lawsuit?  A master complaint in the context of class action or multidistrict litigation (MDL) is a comprehensive legal document that consolidates and presents common factual allegations and legal claims on behalf of a large group of plaintiffs who have been similarly affected or harmed.

But the Master Complaint does not stand alone. Each affected individual has the right to submit their personal claims, adding unique details specific to their experiences.  Every one of these stories is its own unique tragedy, and we can never lose sight of that.

The Master Complaint in the Camp Lejeune class action (yet not a class action) lawsuit is really good.  So we will summarize it here.

Background Facts

Marine Corps Base Camp Lejeune is a U.S.-operated military base situated outside Jacksonville in Onslow County, North Carolina. Spanning across an impressive 156,000 acres with about 11 miles of shoreline, the base currently houses a population of around 170,000 people.

In 1941, the U.S. Congress sanctioned funds for the establishment and construction of a military base that would later be named Marine Barracks Camp Lejeune by 1942. This was subsequently renamed to Marine Corps Base Camp Lejeune in 1944. Ever since its establishment, the base has been integral to the military operations of the United States.  These are the people that have kept us all safe.  But while they were keeping us safe, the government was putting our Marines and their families in jeopardy.

Water Distribution Systems

Understanding the water infrastructure is crucial to comprehending the extent of contamination. Camp Lejeune was sectioned into multiple water distribution systems, notably including Hadnot Point, Holcomb Boulevard, and Tarawa Terrace. Each system had its water treatment plant. These plants employed a lime softening process, which was ineffective in filtering out volatile organic compounds (VOCs), allowing them to seep into the main water reservoir and, subsequently, the distribution system.

Certain supply wells were particularly associated with major contamination sources like the Hadnot Point Industrial Area, the Hadnot Point Landfill Area, and ABC One-Hour Cleaners.

Additionally, there were instances when water from one system was used to supplement another, leading to the potential cross-contamination of water supplies.

Let’s look at the housing areas themselves:

Hadnot Point

Hadnot Point is located south of both Holcomb Boulevard and Tarawa Terrace. Early on in the 1940s, as Camp Lejeune expanded its influence, Hadnot Point saw the establishment of critical facilities like the Water Treatment Plant, the Fuel Farm, and many source wells.

Hadnot Point wasn’t just any random facility. It was a hub. It housed the majority of unmarried military personnel and was central to operations. From the 1940s till about 1972, Hadnot Point also supplied water to several other bases. Its significance can’t be overstated.

The Fuel Farm, built in 1941, boasted a massive storage capacity – up to 792,000 gallons of fuel, to be precise. Alarmingly, its proximity to key water supply wells, particularly well HP-602, was just about 1,200 feet. The potential risks of such a close association are evident.

Issues began surfacing in the 70s.  The introduction of supply well HP-651 next to the defense property disposal compound – which had been functioning as a dumping ground for junk and solvents for years – was a ticking time bomb.

The 1980s brought more dark revelations. Frequent water samples from Hadnot Point consistently unveiled alarming contamination levels of harmful compounds.  Benzene levels in drinking water were so high that they exceeded safe levels for both children and adults for several years! And the frequency of these findings underscores that such contamination wasn’t just an occasional oversight; it was persistent and long-standing.

The government later disclosed that an enormous quantity of fuel – more than 21,000 gallons annually – was being lost into the soil. This raises the question: just how early did this contamination start?

It’s heartbreaking to think of the impact on those stationed at Hadnot Point. The government, to its credit in later years, admitted to significant contamination in Hadnot Point’s water systems. This isn’t just about violations of EPA standards – it’s about people, their health, and their trust.

Holcomb Boulevard

Holcomb Boulevard, positioned between Hadnot Point and Tarawa Terrace, stands out as a significant area on the Area and Well Maps. While it was being served by the Hadnot Point water treatment plant, the finished water in Holcomb Boulevard had been notably contaminated up until 1972.

The launch of the Holcomb Boulevard water distribution system in 1972 was meant to rectify the situation. A series of new supply wells, water treatment plants, and reservoirs were constructed to ensure clean water. However, the system continued to receive supplemental water from Hadnot Point until 1987, bringing forth a continued possibility of contamination.

Holcomb Boulevard wasn’t just a random area; it was a primary housing section on the base. Notably, it provided homes to Midway Park, Paradise Point, Watkins Village, and Berkeley Manor housing among others. While it didn’t have direct sources of contamination like Hadnot Point, it was interlinked with it. The interconnection meant water could be transferred between the two, which, as records show, led to contamination levels in Holcomb Boulevard that were significantly higher than EPA standards.

A disturbing incident in 1985 saw a gasoline leak at the Holcomb Boulevard water treatment plant. The aftermath forced the plant to shut down for nine days. During this period, water from Hadnot Point was channeled to Holcomb Boulevard, resulting in high contamination levels.

Officially, the government’s position is that instances where water from Hadnot Point was routed to Holcomb Boulevard were rare. This assertion raises eyebrows, especially when considering that the data used is based on partially documented valve openings.  Moreover, the treatment plant’s water was used for watering two golf courses, leading to frequent water shortages and thus more reliance on Hadnot Point’s water.  Pragmatically, the first Camp Lejuen settlement offer did include distinguishing where victims were on the Marine base which tells you they do not believe this argument will fly.

The missing documents further this narrative. Crucial documents related to the operation of the control valves are missing.  For instance, a reading of 1,148.4 ppb TCE at Berkley Manor Elementary School in February 1985 underscores the heightened exposure to contamination when water was transferred from Hadnot Point.

Tarawa Terrace

Tarawa Terrace stands out as the northeastern region on the Area Map and the northern region on the Well Map. It is situated north of Holcomb Boulevard and to the east of Camp Johnson.

The Tarawa Terrace subdivision, including its own water treatment plant and distribution system, was completed in 1952. Notably, some initial supply wells were constructed near commercial areas, including dry cleaners and gas stations. Supply well TT-26 was drilled only 95 feet deep, even though the average depth for Camp Lejeune wells was around 180 feet.

By 1953, a dry cleaner named ABC began operations near well TT-26. ABC’s use of PCE, a solvent, led to both liquid and solid waste disposal that potentially contaminated the nearby well.

The United States acknowledges that PCE levels surpassed acceptable limits from 1957 to 1985. After a 1985 incident at the Holcomb Boulevard plant, Tarawa Terrace wells were tested. High contamination levels were found, leading to the shutdown of certain wells in February 1985. However, they were reopened during water shortages.

Records indicate that by March 1987, the Tarawa Terrace water treatment plant was closed. The decision to close was made after considering potential health risks against the need for water supply. Until its closure, PCE levels were high, exceeding acceptable limits in almost every month.

Furthermore, the Tarawa Terrace water distribution system was interconnected with the Camp Johnson system, suggesting potential cross-contamination. Concerns arise that contaminated water may have also been present in the Camp Johnson system during this period.

Water Buffaloes

“Water buffaloes” are not a location on Camp Lejuene. They are portable 400-gallon tanks on trailers, used to store and transport water. These were used extensively during Camp Lejeune’s field training exercises, allowing service members to conduct exercises away from regular water sources.

In a concerning revelation, many of these water buffaloes were filled with water from the Hadnot Point water distribution system, which was contaminated. Thus, during these exercises, which could last hours or even days, service members consumed water with elevated levels of contaminants. The frequency of these trainings was notable, with marines typically spending about three days every week in such activities.



It wasn’t just Hadnot Point. Water buffaloes filled from this location and potentially other contaminated sources were used extensively throughout Camp Lejeune, covering a vast range of regions on both the east and west sides of the New River. This contamination wasn’t restricted to Camp Lejeune either. Water buffaloes filled with this water were also used in field exercises outside Camp Lejeune, like Marine Corps Auxiliary Field Bogue.

Importantly, this exposure wasn’t just from drinking. The water was used for multiple purposes like showering, cooking, and even inhalation from its evaporation. Given the vigorous nature of military training and the warm weather conditions, marines were likely to consume and be exposed to a significant amount of this water.

Recognizing the gravity, the United States admitted that everyone at Camp Lejeune was potentially exposed. The means of exposure varied, but whether through drinking, showering, or even just breathing in evaporated water, the exposure was significant. Considering the volume of water marines would consume, especially during rigorous training, the implications of this contamination become even more severe.

Historic Nature of This Case

Scientists have described it as the most severe public drinking water contamination incident in U.S. history. Records indicate that between 1953 and 1987, the base supplied contaminated water to its inhabitants. Estimates suggest that up to a million people might have been exposed to this compromised water supply, including service members, civilian staff, and their families.

Tests revealed that the contamination levels in the water were alarmingly high, with levels exceeding current EPA safety standards by up to 280 times. This led to a range of severe health conditions in many of those exposed, ranging from various types of cancers, like leukemia, lung cancer, and breast cancer, to conditions like Parkinson’s Disease and female infertility. These severe health impacts have been recognized and linked to the contaminants found at Camp Lejeune.

What caused these illnesses?  Various contaminants were identified in the water supply of Camp Lejeune. Among the most hazardous and prevalent were five VOCs: tetrachloroethylene (PCE), trichloroethylene (TCE), dichloroethylene (DCE), vinyl chloride, and benzene.

The U.S. Environmental Protection Agency (EPA) currently sets regulations on the maximum contaminant levels (MCL) for these compounds, as exceeding these limits poses health risks. The levels of contamination found at Camp Lejeune significantly surpassed these thresholds:

  • The EPA’s MCL for PCE is 5 parts-per-billion (ppb), but water at Camp Lejeune had levels up to 215 ppb.
  • TCE’s MCL is 5 ppb, with Camp Lejeune’s water reaching 1,400 ppb.
  • For DCE, the MCL is 7 ppb, but Camp Lejeune’s levels reached 406 ppb.
  • Vinyl chloride has an MCL of 2 ppb, but the base had levels up to 2.9 ppb.
  • Benzene’s MCL is set at 5 ppb, whereas Camp Lejeune’s water had alarming levels of up to 2,500 ppb.

The Botched Handling of the Disaster Before and After the Fact

The government’s handling of this environmental disaster is disturbing, to say the least, and the Master Complaint makes that clear.  Despite internal warnings, water quality standards were disregarded. Furthermore, crucial information was withheld, even from the government’s own scientists, thereby misleading investigations for years and necessitating retroactive contamination calculations. So if you wonder why the government would pass a law allowing people to sue… the government, it is because they are trying to right a real wrong.

In 1948, a stark warning was already on the record, with a study conducted by the American Petroleum Institute declaring that the only safe concentration for benzene, a toxic chemical, was zero. Despite this knowledge, decisions made in the subsequent years seemed to disregard the risks. Major supply wells were strategically placed in close proximity to contamination sources.

One such well was situated less than a quarter-mile from the base’s primary fuel depot, while another was a mere eighth of a mile downgradient from a business known to dump chemicals into the ground. Yet another well was placed adjacent to a base dump and junkyard that housed metal waste, which had been exposed to TCE, a metal degreaser.

Weaknesses in the Lejeune Infrastructure Were Obvious

Throughout the 1950s and 1960s, multiple studies highlighted the vulnerabilities of Camp Lejeune’s water infrastructure. A 1958 government contractor study emphasized the need for frequent maintenance inspections and repairs for the wells at Camp Lejeune. However, these inspections and necessary repairs were not carried out. Further, in 1959, it was found that the aquifer beneath Camp Lejeune was not adequately shielded from surface contamination. Despite these clear indicators of potential problems, no significant changes were made to mitigate the risk or to consistently monitor for contamination.

Various Navy departments set clear guidelines and standards for water quality during the 1960s and 1970s. These documents recognized the risks, specifically identifying contaminants and the acceptable levels for them. However, repeated test results over the years consistently showed elevated levels of contamination, particularly of chlorinated hydrocarbons, often exceeding the established safe ranges.

Things Did Not Get Better in the 80s

By the 1980s, the issue became even more pressing. Despite having multiple reports and test results indicating contamination, the government not only failed to take corrective measures but also appeared to downplay the severity of the situation. For instance, in 1982, even with test results showing high levels of TCE and PCE contaminants, a memorandum was issued claiming there were no problems detected in several water distribution systems, which is utterly insane.  As a result, they reduced the frequency of testing.

Moreover, communications between different departments and contractors suggest a pattern of withholding or manipulating information. For instance, a 1983 environmental survey omitted any mention of the detected contaminants, even though previous testing had identified them. Additionally, there were instances where the government made commitments to state officials regarding water testing and monitoring, but these commitments were not consistently upheld.

In the early 1980s, the NACIP Initial Assessment Study for Camp Lejeune was notably silent on the alarming contamination already observed, specifically failing to discuss the critical issues found at Hadnot Point and Tarawa Terrace. Instead, the study’s focus was limited to the Rifle Range water distribution system.

Throughout 1983 and 1984, water samples from various distribution systems repeatedly exposed elevated contamination levels. The Facilities Assistant Chief of Staff sent letters and reports about these findings to the North Carolina Division of Health Services. Curiously, instead of attaching the original detailed reports from Grainger, which consistently flagged contamination concerns, these communications contained only a distilled table of the results.

By late 1983, after years of mounting evidence of water contamination, only minimal action was taken to address the contaminated water sources. This slow response continued until well into the 1980s. In 1985, despite the growing body of evidence, decisions were still being made to occasionally utilize contaminated water sources, based on the idea that the potential health threats were not severe enough to warrant shutting them down.

Throughout the late 1980s and into the 1990s, numerous studies sought to gauge the vast and potent harm from this contamination. However, these studies encountered repeated roadblocks, especially with the United States withholding critical data. For instance, it was only in 2009 that the ATSDR gained access to an electronic database, unveiling over 700,000 pages of hidden documents. These documents revealed a startling fact: a massive 1.1 million gallons of fuel had been leaked into the ground at Hadnot Point, far exceeding the previously stated 50,000 gallons.

This late discovery, among others, led to the unprecedented retraction of the ATSDR’s 1997 public health assessment. It became clear that without full transparency and disclosure of all relevant records, it was nearly impossible to provide clear and accurate scientific analyses. Consequently, the true depth of the contamination at Camp Lejeune might still be more profound and devastating than the available studies suggest.

Plaintiffs’ Injuries and Claims

During a significant timeframe, the plaintiffs were exposed to water from various Camp Lejeune water distribution systems, including the Hadnot Point, Holcomb Boulevard, Tarawa Terrace, and Camp Johnson systems. This exposure was due to direct usage and through “water buffaloes,” which were large containers filled from these systems. Such exposure subjected them to dangerous amounts of contaminants. The implications of this exposure were dire, leading to personal injuries or even death for some victims.

The U.S. government really is not denying the premise of this.  It has conceded that exposure to the contaminated water at Camp Lejeune is strongly linked to several diseases. This includes various forms of cancer, Parkinson’s disease, and other serious health conditions. But keep in mind there are suspicions about other contaminants in the water during the relevant period that haven’t been disclosed or studied.  That is still a big gap between what we know and what we will know about what injuries this toxic water caused. Current scientific evidence solidifies the correlation between exposure to the Camp Lejeune water contamination and a wide range of illnesses. Numerous studies are ongoing, aiming to further explore the links between the contaminants and other diseases. So we think it is 40 diseases and cancers.  Who knows what it really is.

One thing is for sure. There’s undeniable evidence linking the injuries suffered by the plaintiffs to the toxic water at Camp Lejeune. This exposure led them to undergo extensive medical treatment, endure physical and mental agony, and in some tragic instances, it resulted in death. The aftermath also entailed other damages such as medical expenses, lost income, and other related costs.

Contact Our Camp Lejeune Water Contamination Lawyers

Our Camp Lejeune lawyers are still helping new clients harmed by exposure to Camp Lejeune water using the following criteria:

  • You served, lived, or worked at the Camp Lejeune Marine Corps base in North Carolina for at least 30 days between the years 1953 and 1987.
  • You were subsequently diagnosed with leukemia, bladder cancer, kidney cancer, liver cancer, multiple myeloma, non-Hodgkin’s lymphoma, or any other condition you believe may be related.

Contact our Camp Lejeune attorneys today for a free consultation at 800-553-8082 or get a free online consultation. Our law firm only gets paid if you receive compensation.


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