ILLINOES

POLLUTION

CONTROL

BOARI)

August

15,

1985

N

THE

MATTER

OF:

)

~OPOSED

AMENDMENTS

~()

)

~UBL

C

WATER

SUPPLY

)

I~EGtJLATIONS,

‘35

ILL.

ADM.

C)DE

602.105

and

602.106

)

~ESSENT.NG

OPINION

(by

J.D.

flumelie):

Everyone

wants

economic

growth.

No

one

wants

industri~it

~xpansion

or

commercial

or

residential

development

halted

i

tiinOis.

But

the

effects

of

this

Emergency

Rule

can

be

to

expose

more

~oo pie

to

levels

of

radium

in

drinking

water

to

four

times

the

cleral

standard

issued

under

the

Safe

Drinking

Water

Act.

The

residential

subdivision

constructed

as

a

result:

o~ the

majority’s action today will remain

in existence far into

thc

future.

The new families moving into those homes may

also

re’~

ide

there

for many years.

The Federal government

is cu~rentlyre-evaluating the radium

:~r~1fl(jard.

But

if

an extended comment

period is granted,

a

Final.

decision may not

be had until

1987.

Then,

if the standard

is

not

materially loosened,

public

water

suppl

ies

would

probably

ne.’d

at

least

three years

to design ~nd

install, radium-removal.

p1arft~.

Thus,

at least five years could elapse.

And,

if no prosecu~ons

are commenced,

a water

supply might

go for

10 years

or more wi~:h

its

present high radium levels unabated.

How dangerous are these high radium levels?

The

pres~igious

Journal

of

the

American

Medical Association

(“JAMA”) pub~ishedan

article

in its August

2,

1985

issue

titled

“Association

of

Leukemia With Radium Groundwater Contamination”

by Lyman, Lyman,

and

Johnson.

(Ex.

21),

The principal author, Dr. Gary

11. Lyman,

is

a physician with an MPH degree.

The study found

a greater

incidence of leukemia in counties with high levels

of radium

in

groundwater than in the counties with low levels

of radium,

The

authors

do not assert

proof

of

a causal relationship between

leukemia and radium in groundwater but recommend further

study.

The authors

point

out that “Almost

85

of the radiation-

induced leukemias occur within 20 years

of exposure,

with

,he

greatest risk observed within five

to

ten

years’

(emphasi:;

Td~T~

(p6~iJ.

As d±scu~sed

ab~VeTe~n

or more years may

eLapse before the existing

high

radium levels

in

‘l1irioi:~

are

brought

down.

The “greatest risk”

will occur

in this

peri~l.

65-333

---

Thu

major

Lty

today

has

allowed

water

slain

ext.ens

)flS

:w)pl.

i

es

with

up

to

four

times

the

Federal

radi

urn

‘~L.:indai’d

.

Thm

nc

~.

pa

1

S

upped

for this

‘Level

comes

From

the

t.

I.

tuony

o I

i chard

F.

Toohey

,

a

nuclear

physicist

at

Argonne

Na Lions

ory

Dr.

Toohey

has

three major

flaws

in

his

pusi~ion

.

lie

1o~hles

the Federal standard by claiming

that

avenge

water

i

i~

;ike

is

one

IL

iter

per

day

and

not

the

two

liters

per day’i~e’.

I~y

‘he Federal government

in setting the standard.

(R.

45-46)

Ilow(?v:~r

Exhihj

t

26A shows

that.

ave

rage

ac,1u1. t

water

i

at at~r,

5

‘~

I

.~rsper day

with

some

indivi.duat.s

consuming

eur

L

iterm;

In’,.

Thus,

Dr. Toohey’s assumed average water

inl~Rc is

for

~

low.

Furthermore,

protection

ought

to

be

afforded

those

‘jlua’Ls

who

consume

four

liters

a

day.

his

second

Flaw

i.s

his

neglect

of

age—and-- ingest

ion

~

ers

.

He

postulates

a

“

threshold”

for

bone

S

ScOmQas

:1).

a

‘IC

i

lose.

This

is

the

case

of

a

7—year

old

boy.

Yet

radi

at

i

in.;

in

“threshold”

.

Are

even

younger

children

more

sons

L ti

vmn

m)WCr’

radium

doses?

Dr.

Toohey’

s

ingestion

absorption

Factor

~i

?~)~

hased

upon

young

adults

does

not

apply

to

infants.

(TL

~

73~.~/4

‘~

They

may

be

bottle

fed

with.

high

radium

local

w~Ler

.ibsorpt

ion

rate

may

well

approach

100.

Lastly,

he

neglects

the

possibility

of

leukemia

vie

‘R.

~5’

and

other

cancers,

Yet

the

JAMA

articl.e

on

FLorida

nenti,aried

above

finds

a

increase

in

leukemia

with

higher

r

it

i.ev~ls

i.n

groundwater.

Dr.

Toohey

Feels

that

only

heal

CsldC

i.nornas

and

osteosarcomas

are

cause(l

by

radium.

Yet

:1

I

virticle

titled

“Drinking

Water

and

Cancer

Incidence

ova’

hy

Judy

A.

Bean,

Peter

‘sacson

,

RolE

M

.

A.

Habne

,

and

.Jrrne~

~oh1

nr

in

the

prestigious

American

Journal

of

Ep~dem,ioto~y_st.~t ui

vi

its

abstract,

“Incidence

rates

o~

an~rsoF

the

lung

and

hLamhInr

among males

and

of

cancers

of

the

breast

and

ilu

Fe~iales

were

higher

in

towns

with

a

radium

-226

level

I

n

the

.~nter supply exceeding

5.0 pCi/i”.

(Ex.

2.6E).

ft

seems

to

me

that

when

j,n

doubt

about

a

material.

whi,eii

ca-s

:nise

eancer

that

one

takes

the

“prudent

man”

approach

and

1 nuni~es

the

exposure

to

that

substance.

I

do

not

agree

with

h-~ majority

that

the

“overwhelming

weight”

of

this

record

-~mistiFies

allowing

more

people

to

be

exposed

to

more

radium.

“lose

radium

means

more

cancer

because

radiation

has

no

threshold.

Q\

~

~

~

(~

c~~~iTf~

~

£hairman

//

V

65-334

---

—3—

I, Dorothy

M. Gunn,

Clerk

of

the

Illinois

Pollution

Control

Board, hereby certify ~iat the above Dissenting Opinion was filed

on

the

~

day

of

________________,

1985.

~.

Dorothy M. c~~nn,Clerk

Illinois

Pollution Control Board

65-335