ILLINOIS POLLUTION CONTROL BOARD
June
20, 1986
VILLAGE OF OSWEGO
)
)
Petitioner,
)
)
v.
)
PCB 85-106
)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent.
)
DISSENTING OPINION
(by J.D.
Dumelle):
The hazard to the public because of the grant of
this
variance may be far greater than apparent.
The Agency’s data gives Oswego’s combined radium level
as
6.7 pCi/i compared
to the State and Federal standards of 5.0
pCi/i.
But Oswego’s data show far higher levels;
that of 13.5
+
1.6 in the southwest portion of the Village and 13.5
+
1.7
in t~Te
Windcrest
Subdivision.
These
levels are more than twice those
reported by
IEPA.
The reason may
simply be in the sampling frequency.
The
Agency samples were taken in four consecutive quarters and
averaged.
The Village’s data are for a single day of sampling,
that
of September
5,
1984.
Thus the Village may have
inadvertently sampled in a high radium level quarter.
Onlymore
sampling will tell for certain.
Radium
is
a known carcinogen.
It killed Madame Marie
Sklodowska Curie and her daughter Madame Irene Joliot-Curie.
It
is a bone-seeker and caused bone cancers.
And over the years
as
it breaks down within the body
it generates radon gas which
causes head cancers.
It also may cause leukemia and other forms
of cancer.
The Federal Register of August
14,
1985 gives the risk as
“between 0.7 and
3 fatal cancers annually per million exposed
persons” at
5 pCi/i of combined radium.
At 6.7 pCi/i the risk
would be
34
higher or 0.9 to
4, averaging 2.5.
If the 13.5
pCi/l level
proves correct,
the fatal cancer risk becomes 170
greatei
or 1.9 to 8.1, averaging 5.0.
Thus every year
,
new residents drinking Osewgo’s water will
incur an individual average fatal cancer risk of 2.5 per million
70-255
-2-
(1-in-400,000) or 5.0 per million (1-in-200,000) depending upon
the correct radium level.
Since
the variance runs for
~
years,
those same risks increase to 1-in-114,000 and 1-in-57,000
respectively over that period.
These are real risks which apply
now.
It is quite possible that the risk given above
is
understated.
The Agency does not cite or provide two recent
studies on cancer
(including leukemia) and radium in drinking
water.
The respected Journal of
the American Medical Association
on August
2,
1985 carried
a pa~~rtitled
r!Association of Leukemia
with Radium Groundwater Contamination” and is authored by a
physician, Dr. Gary
H. Lyman and others.
The article points out
that
“A significant association between leukemia incidence and
the extent of groundwater incidence and the extent of ground
water contamination with radium is reported herein”.
It urges
further studies.
A related paper
is
“Drinking Water and Cancer
Incidence in
Iowa”
by Dr. Judy A. Bean and others.
This appeared
in the
American Journal of Epidemiology (Vol.
116,
No.
6).
A conclusion
was
“Incidence rates of cancers
of the lung and bladder among
males and of cancers of the breast and lung among females were
higher
in towns with
a radium 226 level
in the water supply above
5.0 pCi/i”.
More studies are also urged.
The USEPA is currently evaluating
the radium standard.
It
may well find these two studies and others
so convincing that the
radium standard will be tightened
in
1987.
A major
point at issue
in this and related proceedings is
whether a
“threshold” exists for ionizing radiation effects.
The
Agency’s principal technical expert.
Dr. Richard
E.
Toohey,
feels
that there is
a threshold.
The April
26,
1986 explosion at the Chernobyl nuclear plant
in the Ukraine has raised this same issue.
The New York Times of
May 18,~1986in an article by Malcolm W. Browne
sums up the
controversy as follows:
The long term effects
of relatively small doses
of
radiation include increased susceptibility to
cancer, but these effects are hard to quantify and
remain the subject of scientific controversy.
According to one school of thought,
there may be
a
threshold of
ionizing radiation below which tissues
are able to repair themselves, leaving
a person
essentially unscathed.
But an opposing view is
that any amount of ionizing radiation, however
small, inevitably causes damage of the kind that
can lead
to genetic disruptions
and cancer.
The
difference between these views accounts for the
70-256
—3-
widely varying predictions of the global total of
cancer cases
from Chernobyl’s fallout.
The USEPA risk estimate, mentioned above,
is an annual
risk.
It.
is based upon the
“no threshold” theory.
I agree that there
is no threshold for radiation effects.
Because there is
a real risk to people of cancer and leukemia
from the Oswego drinking water,
I dissent.
I, Dorothy N. Gunn,
Clerk”-’6f
the Illinois Pollution Control
Board, hereby certify that the above Disse ting Opinion was
submitted on the
~‘~—~-~-—-
day of
-
,
1986.
Dorothy
M. Gur~,Clerk
Illinois Pollution Control Board
70-257