PUBLIC HEALTH ASSESSMENT
NEW BRIGHTON/ARDEN HILLS
(a/k/a U.S. ARMY TWIN CITIES AMMUNITION PLANT)
NEW BRIGHTON, RAMSEY COUNTY, MINNESOTA
APPENDIX D: HEALTH OUTCOME DATA
TABLE 19. Number of Persons Reporting Symptoms
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(18 persons total) |
(15 persons total) |
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Source: Reference 32
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Minnesota
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Ramsey County
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Male Female |
34,897 32,944 |
4,025 3,601 |
Black Indian |
1,514 1,223 |
399 92 |
Percent < 2500 grams |
5.1 |
6.3 |
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White Black Indian |
614 31 20 |
65 7 1 |
White Black Indian |
386 19 8 |
47 5 1 |
White Black Indian |
395 16 5 |
37 6 - |
Selected Natality Statistics for Ramsey County: 1985
Minnesota
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Ramsey County
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Female |
32,947 |
4,062 |
Black Indian |
1,975 1,407 |
493 95 |
Percent < 2500 grams |
4.8 |
5.0 |
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White Black Indian |
543 31 9 |
44 9 - |
White Black Indian |
334 20 5 |
27 6 - |
White Black Indian |
378 21 10 |
41 4 - |
Selected Natality Statistics for Ramsey County: 1988
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Minnesota
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Ramsey County
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Live Births
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66,745
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8,276
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Birth Rate
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15.5
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17.5
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Sex: Male
Female |
34,007
32,736 |
4,249
4,026 |
Race: White
Black Indian |
60,150
2,739 1,538 |
6,559
640 117 |
Percent < 37 weeks
Percent < 2500 grams |
6.3
5.0 |
6.1
5.4 |
Congenital Anomalies (%)
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1.5
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1.1
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Infant Deaths: Total
White Black Indian |
521
432 54 16 |
73
51 14 1 |
Neonatal Deaths: Total
White Black Indian |
316
263 33 8 |
39
28 7 1 |
Fetal Deaths: Total
White Black Indian |
466
382 35 17 |
53
41 3 - |
Selected Mortality Statistics for Ramsey County: 1980
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Minnesota
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Ramsey County
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Under 5 years 5-14 years 15-24 years 25-44 years 45-64 years 65 years & over |
2.6 0.3 1.0 1.2 7.5 51.6 |
2.9 0.2 0.8 1.3 8.4 54.4 |
Male Female |
18,138 15,277 |
1,983 1,911 |
White Black Indian Other & Unk |
32,811 325 199 80 |
3,753 111 13 17 |
CAUSE OF DEATH:
Major Cardiovascular Neoplasms - Malignant Respiratory Unintentional Injury Diabetes Mellitus Suicide Chronic Liver Disease Infective-Parasitic Nephritis, Nephrosis Congenital Anomalies |
16,963 6,964 2,411 1,806 497 440 329 226 231 264 |
1,974 879 247 143 67 46 44 26 29 40 |
Selected Mortality Statistics for Ramsey County: 1985
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Minnesota
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Ramsey County
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Under 5 years 5-14 years 15-24 years 25-44 years 45-64 years 65 years & over |
2.1 0.2 0.7 1.0 7.2 52.4 |
2.0 0.2 0.6 1.2 8.2 55.8 |
Male Female |
17,910 16,883 |
1,907 2,109 |
White Black Indian Other & Unk |
34,113 362 199 119 |
3,860 117 14 25 |
Major Cardiovascular Neoplasms - Malignant Respiratory Unintentional Injury Diabetes Mellitus Suicide Chronic Liver Disease Infective-Parasitic Nephritis, Nephrosis Congenital Anomalies |
16,456 7,560 2,969 1,550 560 457 333 300 306 219 |
922 343 150 69 52 45 40 35 22 |
Selected Mortality Statistics for Ramsey County: 1988
Minnesota
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Ramsey County
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Under 5 years 5-14 years 15-24 years 25-44 years 45-64 years 65 years & over |
0.2 0.7 1.2 6.6 52.2 |
2.2 0.3 0.4 1.4 7.0 52.6 |
Male Female |
18,022 17,413 |
1,869 2,186 |
White Black Indian Other & Unk |
34,676 427 224 109 |
3,867 143 13 32 |
Major Cardiovascular Neoplasms - Malignant Respiratory Unintentional Injury Diabetes Mellitus Suicide Chronic Liver Disease Infective-Parasitic Nephritis, Nephrosis Congenital Anomalies |
15,960 8,100 3,220 1,489 556 486 295 418 301 223 |
930 371 128 47 24 41 58 30 32 |
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Cancers for Selected Sites: Ramsey County, 1988
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Hodgkin's Lymphoma
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Non-Hodgkin's Lymphoma
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Multiple Myeloma
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Lymphocytic Leukemia
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Granulocytic Leukemia
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All Cancers
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Expected number of cancers is based on the distribution in the entire state.
Comparison values used in public health assessments are compared to contaminant concentrations in specific media on and off site. Contaminants that exceed comparison values are further evaluated in the Public Health Implications section of this document. Comparison values include Environmental Media Evaluation Guides based on both EPA and ATSDR health guidelines (RMEGs and EMEGs), Cancer Risk Evaluation Guides (CREGs), and other relevant guidelines. CREGs are estimated contaminant concentrations based on one excess cancer case occurring in a million persons exposed over a lifetime. CREGs are calculated from EPA's cancer slope factors. EPA's Maximum Contaminant Level Goal (MCLG) is a drinking water health goal. EPA believes that the MCLG is a level at which no known or anticipated adverse effect on the health of persons should occur and allows an adequate margin of safety. Proposed Maximum Contaminant Level Goals (PMCLGs) are MCLGs that are being proposed. Maximum Contaminant Levels (MCLs) are contaminant concentrations that EPA deems protective of public health (considering the availability and economics or water treatment technology) over a lifetime (70 years) at an exposure rate of 2 liters of water per day. MCLs are regulatory concentrations; PMCLGs and MCLGs are not. EPA's Reference Dose (RfD) and Reference Concentration (RfC) are estimates of the daily exposure to a contaminant that is unlikely to cause adverse health effects.
Comparison values used in the Environmental Contamination and Other Hazards and the Public Health Implications sections of this public health assessment are listed and described below.
* CREG= Cancer Risk Evaluation Guides
* DWEL= Drinking Water Equivalent Level (µg/L)
* EMEG= Environmental Media Evaluation Guides (based on ATSDR MRL)
* MCL = Maximum Contaminant Level (µg/L)
* MCLG= Maximum Contaminant Level Goal (µg/L)
* MRL= Minimal Risk Level (mg/kg/day)
* PEL= Permissible Exposure Limit (mg/m3)
* REL= Recommended Exposure Limit (mg/m3)
* RfD= Reference Dose (mg/kg/day)
* RMEG= Reference Media Evaluation Guide (based on EPA RfD)
* ppm= milligrams per liter (mg/L water)
= milligrams per kilogram (mg/kg soil)
* ppb= micrograms per liter (µg/L water)
= micrograms per kilogram (µg/kg soil)
* kg= kilogram
* mg= milligram
* µg= microgram
* pg= picogram
* L= liter
* m3= meters cubed
* mg/g= milligrams/gram (mg/g food)
Cancer Risk Evaluation Guides (CREGs) are estimated contaminant concentrations that would be expected to cause no more than one excess cancer in a million (10E-6) persons exposed over a lifetime. CREGs are calculated from EPA's cancer slope factors.
The drinking water equivalent level (DWEL) is a lifetime exposure level specific for drinking water (assuming that all exposure is from that medium) at which adverse, noncancer health effects would not be expected to occur.
Environmental Media Evaluation Guides (EMEGs) are based on ATSDR minimal risk levels (MRLs) and factor in body weight and ingestion rates. Reference Dose Media Evaluation Guides (RMEGs) are the same as EMEGs, but they are based on EPA reference doses (RfDs).
Maximum Contaminant Levels (MCLs) are contaminant concentrations that EPA deems protective of public health (considering the availability and economics of water treatment technology) over a lifetime (70 years) at an exposure rate of two liters of water per day (for an adult).
Maximum Contaminant Level Goals (MCLGs) are drinking water health goals set at levels at which no known or anticipated adverse effect on human health is expected and which allow an adequate margin of safety. Such levels consider the possible impact of synergistic effects, long-term and multi-stage exposures, and the existence of more susceptible groups in the population. When there is no safe threshold for a contaminant, the MCLG should be set at zero.
A Minimal Risk Level (MRL) is an estimate of daily human exposure to a chemical (in mg/kg/day) likely to be without an appreciable risk of deleterious effects (noncancer) over a specified duration of exposure. MRLs are based on human and animal studies and are reported for acute (< 14 days), intermediate (15-364 days), and chronic (> 365 days) exposures. MRLs are published in ATSDR toxicological profiles for specific chemicals.
The Occupational Safety and Health Administration's Permissible Exposure Limit (PEL) in air is an 8-hour, time-weighted average developed for the workplace. The sum of exposure levels averaged over 8 hours must not exceed the limit. The National Institute of Occupational Safety and Health also develops and periodically revises Recommended Exposure Limits (NIOSH RELs) for hazardous substances or conditions in the workplace. The NIOSH RELs are time-weighted average concentrations for up to a 10-hour workday during a 40-hour workweek.
EPA's Reference Dose (RfD) is an estimate of the daily exposure to a contaminant that is unlikely to cause adverse health effects. However, RfDs do not consider cancer effects.
APPENDIX F: RESPONSE TO PUBLIC COMMENTS
ATSDR issued a draft Public Health Assessment for public comment in November 1993. The draft document was sent to the public repository at the TCAAP and to two public libraries in Ramsey County. ATSDR also held public availability meetings on December 7 and 8, 1993, at the New Brighton City Hall. The comment period closed on December 20, 1993. No written or verbal comments were received from individuals or citizen groups.
The EPA, the City of New Brighton, the Minnesota Pollution Control Agency (MPCA), and the Army all provided written comments on the draft document. Several of the MPCA comments pointed out the need for correction of environmental measurements reported in the public comment draft public health assessment. Pertinent information, corrections, and many of the editorial suggestions in the written comments were incorporated into this document. Editorial and data correction comments are not summarized below if the response to the comment was a simple correction or editing change. The comments and responses that involve more complex issues than editing or data corrections are summarized below. Such comments are highlighted in bold print.
The page numbers referenced in the comments refer only to pages in the November 1993 public comment release of the public health assessment.
1. Based upon the length of time that has elapsed since the discovery of groundwater contamination at the site, the population shifts that have likely occurred in the affected areas, and the unknowns associated with past completed exposure pathways, some federal and state agencies questioned whether sufficient relevant data are available to conduct a reliable community health investigation, as recommended in the report. Likewise, the potential inclusion of area residents in the TCE subregistry would seem equally questionable for the same reason. The agencies emphasized their position that all of the factors necessary to the conduct of health studies that can yield valid conclusions should be considered very seriously in determining whether such follow-up public health investigations and activities should be initiated.
ATSDR staff members feel that it is difficult, although possible, to gather all needed data at sites with historical human exposure of more than 10 years. That is why ATSDR will first evaluate the feasibility of conducting a community health investigation (stated on page 61 in the public release draft). All the factors listed in EPA's comments, as well as many others, will be considered during the feasibility evaluation.
2. The discussion of environmental contamination and other hazards, which begins on page 16, utilizes various comparison values (CREGS, EMEGS, LTHAs, and RMEGs) in Tables 1 through 10, against which maximum contaminant concentrations found in various wells are compared. While these comparison values are derived from current health guidelines, these comparison values should also include the Safe Drinking Water Act maximum contaminant levels (MCLs), which are the EPA-promulgated standards for acceptable levels of contaminants in public drinking water supplies.
The public health assessment follows ATSDR's published guidance on the use of comparison values. MCLs are considered during evaluations of contaminants of concern when health-based criteria are not available. However, MCLs are based not only on health studies but also on economic and technological considerations. Therefore, ATSDR uses EMEGs for comparison values.
3. Tables throughout the report present the maximum detected concentrations of site-related contaminants. However, the tables do not provide information on detection frequency and range of detected values. This information would be important for assessing the degree of risk posed by these contaminants.
Neither frequency of detection nor range of values is especially useful or important in determining the degree of risk. Such information cannot be used to estimate the dosage of contaminants that the affected population may have ingested, inhaled, or absorbed through dermal contact. Since environmental monitoring is seldom adequate to determine the variability of contaminant concentrations over time, the prudent public health approach is to use the known maximum concentrations to estimate the maximum dosage.
4. Page 37, paragraphs 1 and 2
In the first paragraph, the report notes that surface water concentrations are not above drinking water standards. It is not clear why this comparison is made. It would be more appropriate to compare contaminant concentrations in surface water to ambient water quality standards.
Ambient water quality standards are related more to ecological considerations than health criteria. Although ingestion of surface water is highly unlikely, it was decided to use drinking water standards to clarify and support the health assessors' contention that reported contaminant concentrations did not pose a public health concern.
5. Page 39, paragraph 6
This paragraph is misleading insofar as it questions the detection limits at which contaminants are analyzed. In general, analytical detection limits must be low enough to allow for the evaluation of contaminant concentrations against MCLs. While detection limits used in older reports may have been high, this is not true for the significant data that have been collected for the on-TCAAP remedial investigation (RI), the off-TCAAP RI and the TCAAP annual monitoring report.
In general, analytical detection limits are adequate. The text has been modified to note that only some of the chemicals, such as vinyl chloride, had detection limits above health comparison values.
6. Page 50. paragraph 1
There is no basis for postulating the placement of contaminated sediments at points of human exposure, particularly playgrounds and residential areas. This is extremely unlikely.
Dredging of lakes and ponds is a common occurrence. Contaminated sediments have been transported to points of human exposure at other Superfund sites. However, the paragraph has been revised to indicate that there are no known plans for such dredging at Round Lake.
7. Page 58, paragraph 1
The purpose of referring to a flawed and controversial study, which suggested an association between leukemia and TCE ingestion, is unclear.
The study is included because ATSDR prefers to provide as complete an answer as possible and avoid ignoring published studies. The study was an attempt to investigate the association; however, some researchers disagreed with the study design and interpretation.
8. Within the 25-square mile New Brighton/Arden NPL Site, TCAAP is one of several public and private areas contaminating the underlying units 1, 3, and 4 aquifers. It needs to be clear to the general public that this NPL Site public health assessment focuses specifically on the 4-square mile TCAAP site and contamination emanating from it. It is not a blanket health assessment of the entire NPL site area.
ATSDR has attempted to clarify this issue by revising the Background section of the public health assessment.
9. Please revise your Special Note for People using New Brighton or St. Anthony Municipal Water Supplies to include people using TCAAP municipal water supplies. The TCAAP supply is in full compliance with all state and federal drinking water standards based on information provided by the Minnesota Department of Health. Add Mr. Michael R. Fix, Commander's Representative, Twin Cities Army Ammunition Plant, New Brighton, MN 55112-5700 as the POC.
The TCAAP water supply system was added to the Special Note.
10. Page 2, 1 sentence. Add TCAAP to the list of municipal water supplies meeting all state and federal standards.
Discussion of the TCAAP water supply wells in the body of the report clearly indicates that the operation of the water treatment system prevents human exposure to the groundwater contaminants for the workers on TCAAP. However, to emphasize this safety of the TCAAP drinking water supply, the TCAAP water supply system was added to the list.
11. Page 2, 4th paragraph, 2nd sentence, Please add the Army to the list of agencies that have undertaken special efforts to identify all wells threatened by TCAAP contaminants.
The discussion in the body of the report clearly describes the Army as an agency sponsoring the well inventory. To emphasize this point, we added the Army to the list of agencies in the summary.
12. With regard to comment 2, in a letter dated December 6, 1993, the MPCA staff has made this comment previously and also has stated that State of Minnesota Health Risk Limits (HRLs) and Recommended Allowable Drinking Water Limits (RALs) should be included for private water supplies. HRLs and RALs are based on a 10-5 risk level.
Minnesota HRLs and RALs are regulatory standards that are enforced by state agencies and are not part of the ATSDR health assessment process. As described in Appendix E of the public health assessment, ATSDR relies primarily on health comparison values to select contaminants for further evaluation and discussion in the public health implications section of the public health assessment.
13. Page 2, Paragraph 5
Change "prevent" to "regulate installation of new wells." Also, change "issuing drilling advisories" to "establishing a special well construction area." The MPCA staff's reasoning is that "drilling advisories" is an outmoded term. The current term in Minnesota Rules ch. 4725 involves establishing special well construction areas that regulate construction of new wells so that exposure does not occur above levels of concern and contamination is not spread within an aquifer or between aquifers. Also, add a sentence that the South Plume will be included in the special well construction area.
Paragraph 5 has been revised to follow strictly the language of the selected remedy as approved by MPCA, EPA, and the Army. The Background section now incorporates MPCA's commitment to special well construction areas and regulation of new wells in the South Plume.
14. Page 5, Last paragraph
Although several other suspected sources of contamination have been identified, several of these other sources have been investigated and found not to have impacted the Unit 3 or 4 aquifers. Clarify that the list of suspected sources of contamination is provided in the Phase IA RI report.
A sentence was added to include a reference to the Phase IA RI report.
15. Page 9, Paragraph 1
Modify the statement that "The second operable unit (OU-2) consists of the on-TCAAP soils, sediments, surface waters, and groundwater" to include a statement that OU-2 also consists of the off-TCAAP surface waters and sediments, such as Round Lake and Rice Creek, as well as the contamination in the Surficial aquifer northwest of Site A.
The description of Operable Unit 2 was derived from the Record of Decision for Operable Unit 1, approved and signed by representatives of MPCA, EPA, and the Army.
16. Page 15
The report states that there is recreational hunting around TCAAP. Hunting has long been prohibited in the townships surrounding TCAAP.
The sentence has been revised as suggested.
17. Page 22, Paragraph 4
Modify the sentence that starts with the words "Currently, additional surface water... to read "Additional surface water and sediment samples were taken in the spring of 1993 and were analyzed as part of the feasibility study for Operable Unit 2."
The sentence has been changed as suggested.
18. Page 23, Paragraph 1
There is no reference in the Ecological Assessment to trichloroethane being found in Sunfish Lake. Please correct accordingly.
The high level of cyanide (17.7 ppb) was not found in the lake itself, but in the inlet waters. This distinction should be clarified in the text.
Source documents were checked, and ATSDR agrees with the comment that trichloroethane was not reported in the Ecological Assessment. However, Federal Cartridge Company reported 1,1,1-trichloroethane in a 1988 sample from Sunfish Lake. The reference for the TCA was added, and the location of the cyanide was clarified.
19. Page 23, Paragraph 2
Values for lead and copper found in sediments are in units of ppb. Change to units of ppm.
Antimony in Sunfish Lake sediment was found at 426.7 ppm, not 476.7 ppb. Correct both value and units reported.
The final Ecological Assessment was checked, and figure 23 of that report indicates sediment samples in ug/g, which converts to ppm. However, the antimony concentration reported in the Ecological Assessment was different from that reported in the Army RI, which reports the antimony concentration as 476.7 ug/g in Table 10.5, page 10-24 of Volume 1.
20. Page 25, Paragraph 2
There are more than three areas of private well contamination that are documented. The area that is missing is the remainder of the North Plume downgradient of Highways 10 and 8, and it includes Lowry Grove Trailer Park and several others.
An additional sentence with the MPCA statement and reference has been added to the paragraph.
21. Page 28, Paragraph 3
Clarify the fact that the 1 private well out of approximately 50 sampled private wells refers to the wells in the Edgetown Acres subdivision.
Modify the sentence that "These residences are now connected to the Shoreview municipal water supply" to indicate that not all Unit 1 residences with detections in water samples collected from their wells are connected to the Shoreview municipal water supply.
Corrections were made.
22. Pages 36 through 39, Sediments
The comparisons made between sediment contamination values and human health risk numbers are questionable. Although it is true that adequate comparisons are difficult to obtain for sediments, the report should make it clear that these comparisons are in lieu of better and more appropriate ones.
This comment does not seem to be relevant to the discussions on pages 36 to 39, because there is no mention of human health risk numbers on those pages. ATSDR does not discuss or calculate human health risk numbers in the Environmental Contamination and Other Hazards section of the public health assessment.
23. Page 37, Paragraph 4
The report should make mention of the extensive sampling of Rice Creek surface water and sediment for the Feasibility Study.
The paragraph has been modified.
25. Page 37, Paragraph 5
The MPCA staff has previously requested three times, two of which are in writing, that ATSDR delete this paragraph, as it is not pertinent to TCAAP, and is requesting again that the paragraph be deleted. Also, delete the sentence indicating that MPCA determined that TCAAP was not the source of the TCE because of the distance between TCAAP and the sampling locations, as this statement is not correct. In fact, the focus of the investigations for Round and Long lakes was to define the types, extent, and magnitude of contamination from the Northwest Refinery and Trio Solvents sites to shallow groundwater and their potential contribution to the contamination in the deeper confined aquifers, including the deeper aquifers affected by TCAAP. There is no groundwater connection between the aquifers with TCAAP contamination and Long Lake or Rush Lakes.
The discussion is included for completeness. Quotes from MPCA comments have been added to improve the accuracy of the discussion.
26. Page 51, Number 4
Modify the sentence that reads "Another exposed population was workers who used commercial or industrial wells in the New Brighton area for workplace drinking water supplies." This sentence is not true for all commercial and industrial establishments and needs to be modified to state specifically which commercial or industrial wells in the New Brighton area contained contaminated groundwater above levels of concern.
The sentence has been modified to indicate exposure for workers who used contaminated commercial or industrial wells for workplace water supplies.