Achieving Compliance with the Radium Standards for Drinking Water in a Midwestern Community: A Case Study.

Abstract

The problem of elevated levels of radium in the drinking-water supply of DeKalb, Illinois, a Midwestern community about 65 miles west of Chicago with approximately 35,000 residents, has been a contentious issue for over a decade. The central players in the controversy include a group of concerned citizens, city officials, the Illinois Pollution Control Board, the Illinois Environmental Protection Agency, and the U.S. Environmental Protection Agency (U.S. EPA), Achieving a satisfactory resolution to the problem has been a long, drawn-out process that illustrates how ill-timed proposals, changing risk assessments, different perceptions of risk, and the high costs of compliance can influence the direction of risk management decisions. The purpose of this study is to analyze how these factors sustained the debate and prevented an expeditious solution to the problem. The study uses document analysis as its primary research tool. The questions raised by the controversy, along with their implications for environment al policy, are discussed, as are some of the more important lessons learned from the case. Because of many uncertainties, there were no clear winners in the controversy, although, in the context of the most recent U.S. EPA risk assessments, the community is now poised for better protection from the potential dangers of radium in drinking water than it might have been had citizen action been absent.

Introduction

The problem of elevated levels of radium in the drinking-water supply of DeKalb, Illinois, has been a contentious issue for over a decade. On one side, a vocal group of concerned citizens has seen the problem as a major public-health issue with long-term adverse consequences for the city's residents, especially the children. On the other side, city officials have tended to downplay the risk and have sought alternatives to complying with the standards, at least in part because of the high costs of compliance. The players in this drama, however,, are not limited to the citizens' group and city officials. The Illinois Pollution Control Board (IPCB), the Illinois Environmental Protection Agency (IEPA), and the U.S. Environmental Protection Agency (U.S. EPA) also joined the cast.

Achieving a satisfactory resolution to this problem has been a long, drawn-out process that illustrates how ill-timed proposals, changing risk assessments, different perceptions of risk, and the high costs of compliance can influence the direction of risk management decisions. This study provides a brief retrospective analysis of how these factors conspired to fuel the debate and delay a mutually agreeable solution to the problem. The questions raised and lessons learned from this controversy may be helpful in other situations involving similar--or different--environmental issues. The analysis proceeds by a review of written policies, official decisions and announcements, proposed plans, memoranda, and other primary and secondary data sources, including official rules and regulations, newspaper articles, and personal interviews where necessary to clarify information in the documents.

Radium and Its Health Effects

Radium is found naturally in the environment in four isotopic forms (Ra-223, Ra-224, Ra-226, and Ra-228) (Molinari & Snodgrass, 1990). Most of the attention of the public-health community has focused on Ra-226 and Ra-228 because they are currently the only isotopes of radium regulated under the Safe Drinking Water Act and because they appear to be more abundant in nature and have longer half-lives than Ra-223 and Ra-224 (Molinari & Snodgrass, 1990). The half-lives of Ra-226 and Ra-228 are 1,600 and 5.76 years, respectively, compared with 11.43 days for Ra-223 and 3.66 days for Ra-224 (Bentor, 1999). Ra-226 is an alpha-particle emitter formed in the fifth step of the uranium-238 decay series, while Ra-228 produces beta particles and constitutes the initial decay product of thorium-232 (Molinari & Snodgrass, 1990). Both isotopes are regulated in drinking water because of concerns about their carcinogenic potential, especially concern about the risk of osteosarcomas (National Research Council [NRC], 1988). The r elevant standards for radium under the Safe Drinking Water Act are 5 picoCuries per liter (pCi/L) for Ra-226 and Ra-228 combined and 15 pCi/L for gross alpha-particle activity, which includes Ra-226 but excludes radon and uranium (U.S. EPA, 1999). It is estimated that over three million people in the United States are exposed to Ra-226 levels above 5 pCi/L, with about 890,000 exposed to levels above 20 pCi/L. Similarly, over one million people are estimated to be exposed to Ra-228 levels above 5 pCi/L, with about 164,000 exposed to more than 20 pCi/L (Life Systems, Inc., 1991). The state of Illinois represents one of two geologic regions in the United States where over 75 percent of the reported violations of the radium standards have occurred (Illinois Department of Nuclear Safety, 1986). According to an article in the Chicago Tribune, 77 municipal water systems in Illinois, serving a combined population of several hundred thousand people, currently exceed the radium standard of 5 pCi/L for combined Ra-226 and Ra-228 (Holt, 1998).

From the health standpoint, radium has an affinity for bone tissue, as might be expected because of its chemical similarity to calcium. Radium can replace calcium bone crystals by surface ion exchange and intracrystalline incorporation. Maximum uptake of radium cations occurs in areas of bone growth and remodeling; thus, young people appear to be at higher risk of radium incorporation into bone tissue than older adults, who tend to have slower metabolisms and less bone remodeling (McLean & Urist, 1968). Although most ingested radium is eliminated from the body within a few days of intake, a certain percentage remains in the skeleton depending on the duration of the exposure, the rate of radium absorption, the nutritional and metabolic state of the individual, and other factors (Fink, 1950).

Health concerns about radium date back more than 75 years (Rowland, 1994). In the early 1900s, radium dial painters used a mixture of Ra-226 and Ra-228 with luminescent properties to paint the faces of watches and clocks. Major exposure occurred when the dial painters inadvertently ingested radium as they used their lips to form pointed tips for their paint brushes (Mullner, 1999). Of the 1,468 exposed workers whom researchers followed, 42 developed bone sarcomas, compared with an expected number of 0.4 (Hallenbach, 1986). This represents a mortality ratio of 105:1. Bone sarcomas can occur in both the axial and the appendicular parts of the skeleton. Cancers of the mandible, ribs, pelvis, scapula, and bones of the arms, hands, and legs have been reported (NRC, 1988). Other cancers that have been associated with exposure to radium include multiple myelomas, breast cancer, and leukemia. For these cases, however, the evidence for the association is not as strong as that for bone sarcomas.

Several studies have attempted to find an association between radium levels in drinking water and adverse health effects. Finkeistein (1994) published findings of a population-based case-control study that examined radium levels in drinking water and their association with mortality risk in Ontario youth. The findings showed an increased risk of death from bone cancer with birthplace exposure to radium at levels as low as 7.0 milli-bequerels per liter (0.19 pCi/L). The overall odds ratio was 1.58 (90 percent confidence limits = 1.01, 2.50). One of the more remarkable findings of this study was the low exposure level at which an association was found. A limitation of the study was an inability to establish precise exposure levels.

In a follow-up investigation, Finkelstein and Kreiger (1996) tested the previous findings with an independent group of subjects for whom complete information on radium exposure could be obtained. The results again indicated an association between the presence of radium in birthplace water supplies and an increased risk of bone cancer. The odds ratio was 1.77 (90 percent confidence limits = 1.03, 3.00). A dose-response relationship, however, was not found.

The Controversy

The city of DeKalb, Illinois, has a population of close to 35,000 and is approximately 65 miles directly west of Chicago and about 35 miles southeast of Rockford, Illinois. This Midwestern city is located in a largely rural county and is the home of a major state university, several small manufacturing and distribution plants, and a number of health-and-human-service organizations. The city has been in violation of the radium standards for drinking water under the Safe Drinking Water Act for at least 10 years because high levels of radium occur naturally in the deep sandstone aquifers from which the community water supply is obtained. Table 1 gives the levels of radium in each of the city's nine wells for the period 1990-1996 (Baxter and Woodman Consulting Engineers, 1999). The average level in the city's water supply today is about 7.6 pCi/L (City of DeKaib, 2000).

In any summary of the controversy about excess levels of radium in the city's drinking water, several key events will serve as important milestones. In February 1991, the city applied for and subsequently received from the Illinois Pollution Control Board (IPCB) a five-year variance from restricted status (IPCB, 1991) despite organized opposition from a group of concerned citizens. A month prior to its application, DeKalb had been placed on restricted status following written notice of a violation of the radium maximum contaminant level (MCL) dated December 26, 1990. Under Illinois law, communities in violation of a federal drinking-water standard are restricted from expanding their water systems. This law effectively limits any residential and commercial developments for which the water supply would have to be extended. In granting the variance, IPCB accepted the city's assertion that denial of the variance would create an "arbitrary or unreasonable hardship" on the city. Support for this contention include d arguments that restricted status would not allow the city to continue construction of eight housing developments already under way and would require a large expenditure of public funds for treatment that might become obsolete in the near future (IPCB, 1991). The latter argument referred to a 1991 U.S. EPA proposal to relax the radium standards (U.S. EPA, 1991). If the proposal had been adopted, the city would have been in compliance with the new standards (see Table 2). In granting the variance, IPCB emphasized that it did not constitute a waiver from the radium standards under the Safe Drinking Water Act. In addition, the conditions of the variance specified sequential steps the city was to follow, including quarterly monitoring for radium levels, retention of professional assistance to investigate compliance options, development of a report showing how compliance would be achieved, and construction of facilities, as necessary, to ensure compliance with the applicable standards (IPCB, 1991).

In June 1996, following the expiration of the original variance, the city, which was still in violation of the radium standard, petitioned IPCB for a five-year extension (IPCB, 1996b). City officials once again maintained that denial of the extension would create an "arbitrary or unreasonable hardship" on the city. They argued, among other things, that they were making satisfactory progress on the terms outlined in the original variance since they had maintained reporting schedules, sought consultation on the problem, attempted to reduce overall levels of radium by altering pumping volumes, and routinely notified customers of noncompliance. They also noted the potential financial burden that would result if facilities were built to comply with the current standard only to see that standard lowered by U.S. EPA in the near future. It is interesting that the city stated in its request that "it was willing to commit to all actions short of final design and construction of appropriate facilities until a final dec ision is made regarding the radium standards" (emphasis added) (IPCB, 1996b, p. 7). Likewise, IPCB confirmed that it was "disinclined to require a municipality to conform, and in the process spend millions of dollars, to a standard that is being federally reviewed" (emphasis added) (IPCB, 1996b, p. 17). In granting the city's request on September 19, 1996, the IPCB acknowledged that city officials had not met all of the requirements of the original variance but argued that they had still acted in "good faith" (IPCB, 1996b).

Dissatisfied with the city's approach to the problem and the board's actions, and concerned about potential health threats from elevated levels of radium in the drinking water, a group of citizens, under the banner "The Children of DeKalb," filed a lawsuit against the city in federal court in December 1996 seeking compliance with the current radium standards. The Children of DeKalb, so named because of the perceived higher vulnerability of children to excess radium exposure, argued, among other things, that the city had not fully complied with the original 1991 variance, which called for construction of facilities to reduce radium no later than four years after the variance was granted, as well as for compliance with the standards by the expiration date of the variance (IPCB, 1991). The lawsuit ended in a consent decree less than a year after it was filed. The decree required the city to develop a compliance plan by June 30, 1999, with final compliance with the standards to be achieved by 2001 (U.S. District Court, 1996). It is important to note that as early as 1988, enforcement of the radium standards was considered a low priority by U.S. EPA for communities with radium levels below 10 pCi/L, or twice the established standard (U.S. EPA, Region V, 1988). Also, as late as 1996, U.S. EPA still allowed the "use of discretion" in enforcing radium standards pending a revised MCL (U.S. EPA Region V, 1996). In fact, IEPA, the primary enforcement agency for the Safe Drinking Water Act in Illinois, had effectively recommended lifting restricted status for many communities in noncompliance (IPCB, 1996a) and was apparently selective in its enforcement of the radium standards. A compliance plan was approved by the city on schedule with projected capital costs of $14 million and net operating costs of about $560,000 per year (Baxter and Woodman Consulting Engineers, 1999). The Children of DeKalb and other concerned citizens continue to monitor the provisions of the consent decree closely, and the issue remains unsettled unt il final compliance is reached and maintained for at least two years according to the provisions of the settlement (U.S. District Court, 1996).

Questions Raised

The controversy over violation of the radium standards in DeKalb raises three important questions that have implications for federal, state, and local policies.

* To what extent should a proposed change in a standard affect current enforcement policy?

* How should a revised risk assessment affect current standards?

* What weight should be attached to public perceptions of risk when risk management decisions are made?

A central issue in the controversy over what to do about elevated levels of radium in DeKalb's drinking-water supply had to do with a rule U.S. EPA proposed in 1991 to make the drinking-water standards for radium less restrictive (U.S. EPA, 1991). Once U.S. EPA announced the proposed rule, the nature of the entire debate changed. Virtually every effort by a group of concerned citizens to force the city into compliance with the standards was met by a proverbial "what if?" What if the proposed rule is adopted? Another equally important factor was the estimated cost of complying with the standards. Had the cost of coming into compliance not been a significant issue, the controversy probably would have been resolved years ago. The high costs of compliance and the possibility that a more liberal standard might soon be adopted, however, were issues too compelling for city officials to dismiss. While DeKalb is not able to meet the current limits of 5 pCi/L for combined Ra-226 and Ra-228 without significant expendit ures of public funds for new treatment facilities, its water supply is already well below the proposed limits of 20 pCi/L for Ra-226 and Ra-228, respectively. This fact provided a persuasive argument that influenced the actions of IPCB, IEPA, and U.S. EPA. Official documents confirm that these two factors were influential in IPCB's decisions to grant the original variance from restricted status in 1991 and its extension in 1996 (IPCB, 1991, 1996b). Other factors were considered, but without these two, it could be argued that the variances might never have been granted. Proposed changes in the drinking-water standards and the high cost of compliance also influenced the enforcement actions of IEPA and U.S. EPA. Internal memoranda and other sources confirm that enforcement of the radium standards was selective depending on the degree to which the standards were exceeded and the potential costs of compliance (U.S. EPA Region V, 1988, 1996; IPCB, 1996a). In a memorandum originating from the Air, Water, Toxics and General Law Branch of U.S. EPA, the chief administrator states that such action is "not legally defensible" and represents "a radical departure from traditional U.S. Environmental Protection Agency (U.S. EPA) enforcement policy" (U.S. EPA Region V, 1989).

Figure 1 illustrates how risk assessments for radium in drinking water have changed over the years. These changes have created a dilemma for U.S. EPA staff who are in charge of regulating allowable levels of radium in drinking water. When risk assessment findings in 1991, for example, appeared to indicate lower risk than a previous assessment in 1976, that result led U.S. EPA to reconsider its current radium standards. Risk assessment, however, is an imprecise science built on several assumptions and the availability of satisfactory data. It is a controversial process, because there is no universal agreement on the adequacy of the assumptions. It is also subject to change as assumptions are modified or new data become available. As illustrated in Figure 1, risk assessments can be used to justify either higher or lower standards. The question remains, however: To what degree should changing risk assessments influence current standards? Most health professionals would probably argue that if the risk is found t o be greater than previously believed, the standards should be made stricter to protect public health. Some of these same proponents, however, may not agree with the opposite position. In other words, if a risk assessment indicates less risk, there may still be some resistance to lowering the standard. Since risk assessments can change as models are refined and more reliable data are gathered, it may be prudent not to be too quick to relax standards until further risk assessments have been completed. The apparent trend in finding lower levels of Ra-226 associated with the same level of cancer risk since 1991 could suggest that the 1976 standard should not be altered (Figure 1). Perhaps the findings in 1991 provided an insufficient basis even for the suggestion that the standards be changed in the first place. Since risk assessments inevitably vary over time, it might be a better policy, from a public health point of view, not to relax standards until several subsequent risk assessments indicate that such action is justified. Detractors will argue that this is an overly conservative stance and one that may be unnecessarily expensive for those being regulated, but the controversy in DeKalb indicates that it may have been a better policy. In this case, it was largely the 1991 proposal to relax the standards that initiated the controversy and sustained nearly a decade of debate, during which the population may have been exposed to an increased risk of cancer. In fact, U.S. EPA is now considering retaining the original 1976 radium standards on the basis of the latest risk assessment, which shows that the proposed 1991 standard, if adopted, would have produced excess lifetime cancer r isks 10 times higher than the upper limit of U.S. EPA's allowable risk range of 1 X [10.sup.-6] to 1 X [10.sup.-4] (U.S. EPA, 2000). The 1976 standard of 5 pCi/L is already estimated to be associated with an excess cancer risk of 1 in 5,000 or twice the upper limit of acceptable risk, but only if all of the radium is in the form of Ra-228 (U.S. EPA, 2000).

Another factor in this case was the way perceptions of risk differed among the concerned citizens on the one hand, and the city officials and enforcement agencies on the other. The concerned citizens as a group tended to view the basis for the radium standards as absolute. Since the legal limit was 5 pCi/L, 6 pCi/L represented too much risk, but 4 pCi/L was acceptable. City officials, IEPA, and U.S. EPA, by contrast, appeared to understand that radium standards lack such precision. The standard-setting process is derived from various assumptions and rules about which there is not always widespread scientific consensus. That is one reason why standards for radium differ in other Western nations. This ostensible difference in risk perception was not adequately addressed in the debate and was thus a factor in the decision of the citizens' group to seek legal action and force compliance with the standard even after the city's minimal efforts at changing pumping schedules were able to bring the level closer to th e legal standard. Well over a decade ago, Peter Sandman (1987) proposed a simple model of how people perceive risks. According to Sandman, risk is a function of hazard and outrage, where hazard pertains to the quantitative nature of the risk and outrage refers to its qualitative aspects. Specifically, hazard is the traditional concept of risk--that is, the probability of an adverse outcome, given potential exposure levels. It is usually stated in terms of projected disease incidence or mortality rates. Outrage, by contrast, has more to do with people's responses to a risk--that is, their perceptions of its seriousness based on a subjective analysis that reflects individual attitudes, fears, and beliefs about the risk. Sandman is convinced that understanding the outrage component of risk will help in predicting community reactions to environmental risks and ultimately in resolving conflicts through better risk communication and management (Sandman, 1993). As a result of his and others' research, he has identif ied 20 outrage factors that tend to increase the public's perception of risk (Sandman, 1993). Some outrage factors that may be relevant to this case include a dreaded potential outcome (i.e., bone cancer), a sense of little control over the issue, lack of trust in the guardians of safety perceived inaction by city officials, potential effects on vulnerable populations (e.g., children), delayed effects, and potential effects on future generations.

Some Observations and Lessons learned

The controversy in DeKalb can be framed in several different ways. From the point of view of the citizens' group, the controversy might be seen as a classic David and Goliath struggle. Individual citizens put their lives on hold to fight for a cause they believed in. At their own expense, they attended and held numerous meetings, researched arcane documents for months on end, made numerous phone calls, retained consultants, photocopied mountains of information, sent detailed letters to various parties, and finally initiated a lawsuit in federal court. They focused single-mindedly on one goal: to see that the law was enforced. For some of these individuals, the fight began in the 1980s and will not end until the city can demonstrate that the standards have been maintained for at least two years. Even at this point it is likely that at least a few of the group will remain watchful in case problems develop. For the city officials, many factors must have been considered as they tried to formulate rational respons es to the growing onslaught of questions, concerns, and protests from residents and their supporters. These considerations probably included the best interests of the city as a whole, especially in light of the potential costs of compliance and the likely effects on city growth and expansion. Their more dispassionate view of the risks posed by excess radium, however, may have led some to believe they were unconcerned about health risks. It is more likely that they just did not see the risks in the same light as the citizens' group. If anything, their views were probably closer to the hazard component in Sandman's model (1987) than that of the citizens' group, given the variety of opinions that were being aired on the topic. They underestimated the power of the outrage of the citizens' group, however. As Oleckno has stated, "Too strong of an emphasis on the 'hazard' portion of Sandman's risk equation also ignores the social dimensions of risk, which should be considered in the risk management phase" (Oleckno, 1995, p. 21). Finally, the enforcement agencies (IEPA and U.S. EPA) were in a sense caught in an emotional bind. They knew the law, but they also believed that it was probably going to change fairly soon and that any enforcement action would result in costly construction that would later be deemed unnecessary. The situation is not so different from that faced by a sanitarian who has to tell an elderly couple living on Social Security that they have to pay several thousand dollars to hook up to new sewer mains even though their septic system has been working flawlessly for the past 35 years. It can be a difficult situation to enforce, but according to a U.S. EPA administrator, not enforcing the law could "destroy environmental enforcement because of the difficulty in predicting which regulations may or may not change in the near or foreseeable future." (U.S. EPA Region V 1989).

So what has been learned from this case? In reference to the previously raised questions, the following conclusions seem to make sense:

* Laws and rules and regulations need to provide for reasonable exceptions. The Safe Drinking Water Act already takes costs into consideration in setting enforceable standards. It also provides a mechanism for granting waivers and exemptions. It does not, therefore, make much sense to determine enforcement policy on the basis of what might occur in the future or what compliance might cost, especially since these predictions do not always materialize as expected. Such was the case in DeKalb.

The 1991 proposed change in the radium standards was never promulgated and probably never will be. Ad hoc policies are likely to be unevenly applied and unfair to those who make the effort to comply with the law. The radium problem in DeKalb is shared by hundreds of other communities in the Midwest and elsewhere. Some of these communities have taken expensive steps to comply with the law, while others continue to resist. Sound policy will provide guidelines in the law for making decisions regarding enforcement rather than developing impromptu policies as the need arises. At the very least, guidelines need to be outlined in the law for developing new policies so that decisions are not based simply on the predilections of the current administration.

* Risk assessment as a process needs to be improved and communicated more clearly to the public. Many still think in terms of safety, often in a dichotomous way They tend to believe that risk assessment is able to establish safe levels of environmental exposures with precision. That is rarely the case unless society is willing to set all limits at zero. The maximum contaminant level goal for radium, for example, is zero, since that is the only dose that is known to be absolutely safe, It is also impractical, and that is why there are MCLs. Any MCL set at a higher level presupposes some risk, but that risk is balanced by practical considerations like detection capabilities and methods available to reduce the contaminant at a reasonable cost. Risk communication has made great strides in recent years, but much remains to be done. According to Oleckno, "The rewards of a proactive, ongoing, and cooperative risk communication program are better informed citizens, increased public trust, and the cultivation of potential allies in the fight for improved environmental health" (Oleckno, 1995, p. 23). In the DeKalb case, efforts at risk communication did not live up to this ideal. The consequences were mistrust and alienation, both of which will probably spill over to future environmental issues involving the city, environmental enforcement agencies, and the public. Also, in retrospect, the proposal to relax the radium standard was based on inadequate information. Current risk estimates favor a lower limit more consistent with the current MCL (U.S. EPA, 2000). There is no doubt that this ill-timed proposal was responsible to a significant degree for the difficulty in resolving the enforcement issue in DeKalb. Once standards have been set, there should be a sound basis for suggesting changes. Whether the risk assessment in 1991 provided a sufficient basis for considering a change in the MCL for radium was not examined in this analysis, but previous research has suggested this was not the case (Sandman & Oleckno, 1997). At any rate, given the potential consequences of such a proposal, it should not have been made lightly. In fact, one may wonder how convincing the assessment was, given that U.S. EPA has taken no action for nine years. In fairness, however, it should be acknowledged that U.S. EPA has strict edicts to follow and that science often moves slower than legislation.

* If the risk of cancer had not been perceived as substantial by a group of concerned citizens, it is unlikely that a sustained effort would have been made to force compliance with the radium standards in DeKalb. Ultimately, enforcement or some legal compromise would have resulted, however, since the 1991 proposal was never promulgated and is not now under consideration (EPA, 2000). When this would have happened is still an open question. Depending on where one stands on the issue, the citizens' group may be heralded as protectors of the public health or the architects of higher water bills in DeKalb. Public perceptions of significant risks, however, can be a powerful force in determining how those risks will be managed. In a democratic society, the marketplace of ideas (and perceptions) can influence how, when, and what decisions are made, but the end result is not always predictable.

Closing Comments

In the final analysis, it is debatable who the real winner was in this protracted controversy. The citizens' group fought hard to win compliance with the radium standards, but the costs of doing so have been significant both personally and for the community as a whole. Estimates indicate that water bills may increase to two to three times their previous levels (Baxter and Woodman Consulting Engineers, 1999). The city officials fought hard to avoid costly construction of what they thought would soon be obsolete measures. They may soon be faced with the displeasure of those who see their water bills increasing to pay for the high costs of compliance. IPCB and IEPA may now have to think about how they will settle similar problems in other communities in the state. Finally, U.S. EPA has to deal with questions of credibility because of its changing risk assessments. Health goals and economics are often at odds, and it will be interesting to see whether, a few years from now the public appreciates the price it had to pay to come into compliance with the radium standards. Unfortunately, data on bone cancers in the community are not available, although the county rate shows no practical difference from that of the state (M. Lehnherr, personal communication, April 29, 1999) (Table 3).

Corresponding Author: William A. Oleckno, Presidential Teaching Professor and Coordinator, Public and Community Health Programs, School of Allied Health Professions, Northern Illinois University DeKalb, IL 60115-2854.

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The references in this paper are formatted according to the new references format adopted by NEHA for articles published in the Journal of Environmental Health. The new format is simpler to use, and is based largely on the style recommended by the American Psychological Association. If you or any of your colleagues are preparing a manuscript for submission to the Journal, please obtain a copy of NEHA's new Instructions for Authors: Contact Vanessa DeArman by phone at [phone], ext. 311, or by e-mail at [less than][e-mail][greater than]. Or you can call our faxon-demand service at [phone], ext. 5, and request document #212.

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U.S. Environmental Protection Agency: National primary drinking water regulations, radionuclides: Notice of data availability, proposed rule, 65 Federal Register 21583-21585 (2000).

               Radium Levels (Ra-226 and Ra-228 Combined)
               in Nine Wells Supplying DeKalb, Illinois,
                   with Drinking Water, 1990-1996 [*]
Well No. [**]  Average Level (pCi/L)  Range (pCi/L)
   1                    4.3              2.5-5.6
   2                    4.7              2.6-6.4
   3                    6.2              4.8-6.9
   4                    6.4              3.6-7.9
   5                    6.4              5.6-7.0
   6                    6.8              6.0-9.1
   7                    9.5              7.3-11.3
   8                   10.1              7.5-12.0
   9                   11.8              8.0-14.4
(*.)Source of data: Baxter and Woodman
Consulting Engineers (1999).
(**.)The well numbers are given for
convenience only. They are listed in
ascending order by level of combined radium.
              U.S. EPA's Proposed Standards for Radium in
                        Drinking Water, 1991 [*]
Radiation Source      Proposed Standard (pCi/L)
Radium-226                       20
Radium-228                       20
Adjusted gross alpha             15 [**]
(*.)Source of data: U.S. EPA (1991) uranium.
(**) Excludes Rs-226, but includes radon and uranium
                     U.S. EPA Assessments of Radium
                   Levels That Pose a Lifetime Cancer
                   Risk of 1 x [10.sup.-4], 1976-2000
1976    5
1991   22
1994   10
2000  6.9
Source: U.S. Environmental Protection Agency (2000).
Note: Table made from bar graph
                 Average Annual Age-Adjusted Incidence
                  Rates for Bone Cancer, 1986-1996 [*]
DeKalb County    State of Illinois
0.9 per 100,000  0.8 per 100,000
(*.)Source: M. Lehnherr (personal communication,
April 29, 1999). Age-adjusted rates
were determined by the direct method of
adjustment based on the 1970 U.S.
Census (rates for both sexes and all races).
With indirect adjustment, the standardized
morbidity ratio is 1.0 (seven cases
observed and seven cases expected).