ILLINOIS POLLUTION CONTROL BOARD
    June 20, 1991
    CITY OF WEST CHICAGO,
    )
    )
    Petitioner,
    )
    v.
    )
    PCB 91—4?
    )
    (Variance)
    ILLINOIS ENVIRONMENTAL
    )
    PROTECTION AGENCY,
    )
    )
    Respondent.
    DISSENTING OPINION (by J.D. Dumelle):
    The water supply of the City of West Chicago has a combined
    radium content of 7.3 pCi/i. That is almost half again the 5 pCi/i
    USEPA standard currently in force.
    The risk to all of the people of contracting head or bone
    cancer is thus a greater risk if the water were at the standard.
    The risk at the standard is 1-in-14,300 over a 70-year lifetime.
    West Chicago’s water, is then about i—in-9,800. (The risk levels
    are contained in Dr. William H. Hallenbeck’s paper “Risk Analysis
    of Exposure to Radium-226/228 in~.Groundwater” published in The
    Environmental Professional, Vol. 11, pp. 171—177).
    When the USEPA sets limits for pesticide residues and for
    other chemicals it commonly uses a lifetime risk of 1-in—l,000,000.
    The West Chicago risk of l—in-9,800 is thus 100 times greater than
    the usual risk used for many other chemicals.
    But that l-in-9,800 risk may be even greater for two groups
    of West Chicago’s population. Three separate research papers point
    to “young children”, “young people”, and children in “periods of
    rapid growth” (“0-1 yr. and 10-16 yr.”) as being at even greater
    risk.
    (~
    Background Document on Radium in Drinking Water,
    Illinois Department of Nuclear Safety, August 25, 1986, p. 5). How
    much greater that risk is to these children we are not told but j~
    is greater than l—rn-9,800.
    An additional concern besides head cancer and bOne cancer is
    leukemia. A 1985 paper, “Association of Leukemia with Radium
    Groundwater Contamination” by Lyman, et al (Journal of the American
    Medical Association) shows a correlation between high radium
    content in water and leukemia. Unfortunately, no one seems to have
    replicated the study in Illinois.
    On June 10, 1991 an article in the Aurora Beacon-News gave
    actual or projected costs for 8 communities to bring their radium
    levels down to the 5 pCi/l standard.
    2
    The table below lists them alphabetically and the per capita
    capita cost is computed. Census figures for 1980 are used except
    in Aurora’s case where the 1990 estimate is given.
    CITY
    COST
    POPULATION
    COST PER CAPITA
    Aurora
    $23,300,000
    99,500
    $
    245
    Batavia
    4,200,000
    13,758
    306
    Channahon
    500,000
    3,788
    132
    Elburn
    1.400,000
    1,224
    1,143
    Geneva
    5,000,000
    9,881
    507
    Morris
    600,000
    8,833
    68
    Ottawa
    983,000
    18,166
    54
    Wiln~ington
    2,500,000
    4,424
    565
    Note that with the exception of Elburn all of the communities
    have per capita costs of $565 or less. In addition to these 8
    communities which authorized their projects to reduce radium levels
    there are two major regional water supply projects that will be on-
    line •about April, 1992 that also reduce existing radium levels.
    These two projects are the DuPage Water Commission’s
    $350,000,000 system to supply Lake Michigan water to 27 communities
    with 750,000 people (per capita cost of $467) and the Central Lake
    County Joint Action Water Agency’s $103,200,000 system serving 8
    communities with 250,000 people (per capita cost of $413) also
    supplying Lake Michigan water.
    West Chicago should intensively study the various options to
    reduce the radium levels in its water. A risk of 1-in—9,800 is
    simply too great for the public to bear. And that risk is even
    higher for infants and children.
    On July 18, 1991 the Federal Register finally published the
    USEPA’s proposed relaxation of the radium standards for drinking
    water. The new risk estimate for 5 pCi/I of either radium isotope
    seems to be 1—in-50,000 as compared to the 1-in—l4,300 mentioned
    earlier. The basis for loosening the risk estimate by a factor of
    3 is not given but is contained in the “Criteria Document” which
    is not readily available. 56FR33073. Even using the new risk
    estimates, West Chicago’s water would have a lifetime risk for
    cancer of l-in-30,000 or 33 times greater than the usual 1-in-
    1,000,000.
    3
    A duty of a city or a state government is to protect its
    people. I urge West Chicago to deeply consider the excessive
    health risks to its citizens from
    radium content of its water.
    ,/Jacob D. Dumelle, P.E.
    /
    Board Member
    1, Dorothy M. Gunn, Clerk of the Illinois Pollution Control
    Board hereby certifyjthat the abov~ Dissenting Opinion was
    submitted on the
    -~i~-
    day of
    _______________,
    1991.
    ~~
    Dorothy M//Gunn, Clerk
    Illinois ~ól1ution Control Board

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