ILLINOIS POLLUTION CONTROL BOARD
    July
    11, 1985
    CITY OF AURORA,
    Petitioner,
    v.
    )
    PCB 85—51
    ILLINOIS ENVIRONMENTAL
    )
    PROTECTION AGENCY
    )
    Respondent.
    CONCURRING OPINION (by J.D. Dumelle):
    The key health testimony in this proceeding contains both
    errors and doubtful assumptions.
    In my view the Board should
    have only given variance from restricted status and not from
    the
    5 pCi/l drinking water combined radium standard itself until
    these matters are adequately explained.
    Dr. Richard
    E. Toohey of Argonne National Laboratory
    presented his testimony at
    the hearing on June
    25,
    1985.
    No
    cross—examination was made.
    A major assumption made by Dr. Toohey was that average water
    consumption
    is only one liter
    a day as compared
    to
    the two liter
    per day figure traditionally used by USEPA
    (R.
    27).
    But no data
    were presented by Dr. Toohey on this point.
    One must remember
    that coffee and soup made with local water must be included
    in
    radium intake computations.
    The boiling process does not, ot~
    course,
    remove or neutralize
    radium.
    A second problem with Dr. Toohey’s testimony
    is his use of
    the
    50 uCi radium intake “threshold”
    in the face of an 8—year—old
    boy getting cancer
    after
    a
    9 uCi intake
    (R. 34).
    This
    immediately raises
    a question as
    to possible lower
    “thresholdst’
    on even younger
    children and on infants.
    Lastly,
    Dr. Toohey’s computations appear
    off by a factor
    of
    4.5.
    If one estimates lifetime
    (75 year)
    intake of
    radium at
    USEPA’S standard of
    5 pCi/l
    Using two liters per day
    it comes
    to
    0.27 uCi not the 0.06 uCi he asserts
    (R. 25).
    Similarly,
    the
    time needed
    to ingest
    10 uCi
    of radium
    is not 13,000 years
    but
    2,740 years or again a factor of 4.5
    (R. 24).
    My concern
    is about
    those who
    are longtime Aurora
    residents.
    They continue
    to take in radium at
    14 pCi/i.
    By
    age
    75 they will have taken
    in 0.77 uCi.
    Is this hazardous?
    We just
    don’t
    know.
    65-65
    The assumption as
    to water intake
    (one liter per day versus
    two)
    seems highly questionable.
    The
    induction of cancer
    in
    a
    child at
    a far
    lower
    level than is being used
    is bothersome.
    Finally,
    the computations appear
    in error.
    I would
    urge USEPA to quickly re—evaluate
    the radium
    standard and clarify its scientific status.
    I,
    Dorothy
    M. Gunn, Clerk of the Illinois Pollution Control
    Board,
    here~,ycertify
    that the above Concurring Opinion was filed
    on the
    ~22
    day of
    QJ~
    ,
    1985.
    ~cd
    ~D
    Dorothy M.lunn, Clerk
    Illinois Pollution Control Board
    tcob 0
    Dumelle, P.E
    Lairman
    I
    65-66

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