ILLINOIS POLLUTION CONTROL BOARD
    March 22, 1990
    CITY OF BATAVIA,
    )
    Petitioner,
    v.
    )
    PCB 89—183
    )
    (Variance)
    ILLINOIS ENVIRONMENTAL
    )
    PROTECTION AGENCY,
    )
    )
    Respondent.
    CONCURRING OPINION
    (by B.
    Forcade):
    I concur with the majority’s request for additional
    information from the Agency.
    However,
    one point deserves
    particular emphasis from the standpoint of human health.
    I
    specifically request that the Agency address this issue in their
    recommendation.
    The Amended Petition filed on March 14,
    1990 shows two years
    worth of analysis on well
    #3 at levels of combined radium of
    about 29 pCi/i. This level
    in drinking water
    is clearly a cause
    for concern.
    The record does not reveal how the water
    distribution system
    is organized.
    It certainly
    is possible that
    those homes nearest well
    #3 would have been supplied with water
    preferentially drawn from well
    #3.
    If so, homes nearest that well
    could have had combined radium levels near 30 pCi/l for many
    years.
    As clearly emphasized
    in the March
    8,
    1990 concurring
    opinion
    there is no support in the record for a conclusion that
    combined radium levels above
    20 pCi/i are safe.
    I sincerely want to know what the Illinois EPA believes are
    the health risks associated with such highly contaminated water
    (six times the current health based standard),
    and what method
    they use to calculate such health risks.
    The Risk Assessment
    document
    (Risk Assessment of Exposure to Radium and Fluoride in
    Illinois Public Water Supplies, R 85—14, Ex.
    45, p.38—41)
    has
    estimated the excess lifetime cancer risk from consumption of
    drinking water containing combined radium concentrations at or
    above 20 pCi/l to be approximately
    1 cancer in 5000 people so~
    exposed. This puts a ceiling on the risk level, which appears to
    be based on the assumption that combined radium concentrations
    would not exceed 20 pCi/l.
    The specific number for actual extra lifetime risk above
    that associated with a combined radium concentration of
    5 pCi/l
    is calculated using the formula provided in the Report
    Extra
    Lifetime Risk
    =
    1.4 x l05(concentration
    -
    5).
    For those water
    supplies at or below the current regulatory health standard of
    5
    109—553

    2
    pCi/i, the lifetime risk would be
    (1.4
    x concentration)
    of
    excess cancers per 100,000 persons exposed to that concentration.
    For a combined radium concentration of 29 pCi/i,
    the extra
    lifetime risk would be 34 x l0~, or
    1 excess cancer for each
    2941 people so exposed.
    I want to know how many people have been
    drinking water at those levels and for how long.
    B111
    Fo cade
    Board Member
    I,
    Dorothy M.
    Gunn, Clerk of the Illinois Pollution Control
    Board, hereby certify that the above Concurring Opinion was filed
    on the
    ~
    day of
    1
    -~
    ,
    1990.
    /
    (
    ~
    (
    /
    /
    /D
    -
    -
    Dorothy M.
    c~unn, Clerk
    Illinois Pp~LlutionControl Board
    109—554

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