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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
Symptom New Brighton Wells
(18 persons total)
Private Wells
(15 persons total)
Headache
2
5
Rash
2
5
Eye Irritation  
1
Abdominal Pain
3
2
Diarrhea
1
6
Fatigue
1
 
Depression
4
2
Dizziness
3
4
Poor Concentration
1
2
Poor Memory
1
3
Tremors  
1
Drowsiness
1
 
Numbness
2
 
Arrhythmias
3
1

Source: Reference 32

Selected Natality Statistics for Ramsey County: 1980
Minnesota Ramsey County
Live Births
67,843
7,626
Birth Rate
16.6
16.6
Sex:
Male
Female

34,897
32,944

4,025
3,601
Race: White
Black
Indian
63,067
1,514
1,223
6,641
399
92
Percent < 37 weeks
Percent < 2500 grams
6.8
5.1
7.7
6.3
Congenital Anomalies (%)
1.3
1.3
Infant Deaths: Total
White
Black
Indian
679
614
31
20
78
65
7
1
Neonatal Deaths: Total
White
Black
Indian
421
386
19
8
54
47
5
1
Fetal Deaths: Total
White
Black
Indian
449
395
16
5
46
37
6
-


Selected Natality Statistics for Ramsey County: 1985
Minnesota Ramsey County
Live Births
67,412
8,242
Birth Rate
16.1
17.9
Sex: Male
Female
34,465
32,947
4,180
4,062
Race: White
Black
Indian
61,095
1,975
1,407
6,829
493
95
Percent < 37 weeks
Percent < 2500 grams
6.3
4.8
6.4
5.0
Congenital Anomalies (%)
1.2
1.2
Infant Deaths: Total
White
Black
Indian
591
543
31
9
56
44
9
-
Neonatal Deaths: Total
White
Black
Indian
364
334
20
5
36
27
6
-
Fetal Deaths: Total
White
Black
Indian
439
378
21
10
53
41
4
-

Selected Natality Statistics for Ramsey County: 1988
   Minnesota Ramsey County
Live Births

66,745

8,276

Birth Rate

15.5

17.5

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 (%)

1.5

1.1

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
  Minnesota Ramsey County
Total Deaths
33,415
3,894
Rate: Age & Sex Adjusted
8.2
8.7
Rate: Sex Adj.-Age Spec.
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
Sex:
Male
Female

18,138
15,277

1,983
1,911
Race:
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

 

Minnesota Ramsey County
Total Deaths
34,793
4,016
Rate: Age & Sex Adjusted
8.3
8.9
Rate: Sex Adj.-Age Spec.
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
Sex:
Male
Female

17,910
16,883

1,907
2,109
Race:
White
Black
Indian
Other & Unk

34,113
362
199
119

3,860
117
14
25
CAUSE OF DEATH:
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

1,811
922
343
150
69
52
45
40
35
22

Selected Mortality Statistics for Ramsey County: 1988
  Minnesota Ramsey County
Total Deaths
35,436
4,055
Rate: Age & Sex Adjusted
8.2
8.4
Rate: Sex Adj.-Age Spec.
Under 5 years
5-14 years
15-24 years
25-44 years
45-64 years
65 years & over

1.8
0.2
0.7
1.2
6.6
52.2

2.2
0.3
0.4
1.4
7.0
52.6
Sex:
Male
Female

18,022
17,413

1,869
2,186
Race:
White
Black
Indian
Other & Unk

34,676
427
224
109

3,867
143
13
32
CAUSE OF DEATH:
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

1,766
930
371
128
47
24
41
58
30
32


1980 Arden Hills Mounds View New Brighton Shoreview
Live Births
131
224
353
255
Fetal Deaths
-
2
3
-
Infant Deaths
2
6
3
4
Neonatal Deaths
2
4
3
1
Deaths
51
28
114
52


1985 Arden Hills Mounds View New Brighton Shoreview
Live Births
117
231
358
341
Fetal Deaths
-
-
3
1
Infant Deaths
1
1
4
1
Neonatal Deaths
-
1
2
1
Deaths
77
32
158
59


1988 Arden Hills Mounds View New Brighton Shoreview
Live Births
130
224
283
385
Fetal Deaths
1
1
-
2
Infant Deaths
-
3
-
-
Neonatal Deaths
-
3
-
-
Deaths
97
50
150
76

Cancers for Selected Sites: Ramsey County, 1988
Cancer Site Males Females
Observed Expected Observed Expected
Lip
11
20.8
3
5.8
Tongue
1
4.3
7
3.7
Gums
3
4.1
6
5.7
Esophagus
12
9.5
2
3.5
Stomach
20
21.4
11
14.6
Small Intestine
0
3.6
1
4.3
Colon
83
88.0
117
110.9
Rectum
43
37.7
31
34.8
Liver
8
5.5
2
2.8
Gallbladder
1
1.8
7
5.9
Pancreas
17
17.7
20
17.9
Larynx
15
15.8
2
2.6
Lung
139
139.9
100
90.8
Trachea & Pleura
2
3.0
0
0.6
Bones & Joints
2
1.7
1
2.1
Soft Tissues
6
7.8
9
6.4
Melanoma
30
26.8
25
28.8
Breast
1
1.4
272
327.6
Cervix
-
-
20
24.4
Uterus
-
-
74
65.2
Ovary
-
-
45
41.6
Vulva
-
-
2
2.6
Prostate
242
240.7
-
-
Testis
18
14.4
-
-
Bladder
49
47.3
26
20.7
Kidney
36
29.2
8
18.2
Eye
2
2.2
1
1.6
Brain
17
16.0
13
14.3
Thyroid
6
5.9
18
19.3
Hodgkin's Lymphoma
10
8.4
6
8.0
Non-Hodgkin's Lymphoma
49
40.7
43
41.4
Multiple Myeloma
15
14.1
9
10.3
Lymphocytic Leukemia
10
15.1
9
10.2
Granulocytic Leukemia
7
10.5
21
13.4
All Cancers
926
915.7
963
1028.0

Expected number of cancers is based on the distribution in the entire state.


APPENDIX E: COMPARISON VALUES

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.


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