ILLINOIS POLLUTION CONTROL BOARD
May 9,
1986
CITY OF YORKVILLE,
)
Petitioner
v.
)
PCB 86—24
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent.
DISSENTING OPINION
(by J.
D.
Dumelle):
My
reasons for dissenting are my concerns over health
effects and
the lack of specificity as
to the hardship.
The Yorkville drinking water
radium content
is 7.8 pCi/l
compared
to
the State
and Federal
standard of
5.0.
It
is thus
56
over
a health—based standard set
to protect against cancer.
The majority Opinion
states,
“For the short
term of the
variance,
any adverse
risk
to the environment would be
minimal.”
Opinion,
p.
4.
The variance granted
by the majority
is
for three years.
Allowing
a full year for any new residential
construction means
a remaining two year exposure
to high radium
for persons moving into those new housing units.
The Federal Register publication of August
14, 1975 states,
“...
the potential risk due
to radium drinking water ingestion at
5 pCi/l
is estimated
to
be between 0.7 and
3 fatal cancers
annually per million exposed persons.”
40 FR.
34325.
The key
word
is “annually.”
Since Yorkville
is
56
over the standard
its risk
figures
then become 1.1 and 4.7 instead
of 0.7 and
3 respectively.
These
average
to
2.9.
If,
in Yorkville,
an average
of 2.9 fatal
cancers will
be induced per million people exposed annually then
it follows that in two years
twice
as many will
be induced
or
5.8.
The chances of getting cancer
in Yorkville
in two years are
then about l—in—172,000.
Are these odds the Board should allow
to be inflicted upon the public?
I
think
not.
The vagueness
of
the hardship
is bothersome.
No projects
are listed as being held
up by Restricted Status.
What then is
the hardship?
And
is
it any different from any other
community
on Restricted Status?
If
it
is not,
then the
rule is useless and
should
be repealed.
I would have no hesitancy in voting
for
a
69-448
—2—
variance
to allow water main improvements
for fire fighting
purposes,
etc.
or even
for office or
commercial structures.
It
is
the new residences that create
24—hour—a--day exposure
to
additional
people.
Some final
words.
The Agency
in its Recommendation repeats
its often—used statements
about
ion exchange softeners using salt
resulting
in possibly dangerous levels of sodium in drinking
water.
Yet
it has never proposed
a sodium standard
to this
Board.
Why not?
Similarly,
it repeats its concern that
radioactive
ion exchange material disposal “may be a problem.”
Is it
or isn’t
it?
Do we not now have enough experience under
RCRA
to know?
How
is existing radioactive
ion exchange waste
disposed of now?
Lastly,
I object
to the majority’s truncated inclusion into
the record
of portions of R85—l4.
The paper “Drinking Water
and
Cancer Incidence
in Iowa”
(Ex.
26E)
is not included.
The Journal
of
the American Medical Association article “Association of
Leukemia with Radium Groundwater Contamination”
(Ex.
21)
is not
included.
To exclude these
and other materials in R85—14
is
to
bias
the record
in this variance and
is not objective.
I,
Dorothy M.
Gunn,
Clefk
of the Illinois Pollution Control
Board,
hereby certify that the above Dissenting Opinion was filed
on the
/~~-
day
of
____________
1986.
/L~/
Dorothy M.
Gz~nn, Clerk
Illinois Pollution Control Board
aco&.~
hairman
69-449