ILLINOIS POLLUTION CONTROL BOARD

January

22, 1981

VILLAGE OF

FLANNA CITY,

)

Petitioner,

v~

)

 PCB 8O~2O6

ILLINOIS

 ENVIRONMENTAL

PROTECTION AGENC~,

)

Respondent

CONCURRING

 OPINION

(by

 Satche~l1):

My

reason

 for concurring in this case is that the

 variance for

gross

alpha particle activity

was

 denied as being

 unproven, based

on evidence

before the Boards

I

 would

have

granted the variance particularly to inform

the

residents

 (Rule

313 D

1)

 that their water supply may

 contain more

radioactivity

 than is deemed in the Board~sPublic Water

Supply

Rules to

constitute an acceptable risk level.

In

support of this action,

 I would offer the

following:

1.

 Radioactivity is

a

uno

 threshold~contaminant, Le.,

any

level

 presents some risk;

2~

 The record provides four values

 (pCi/l)

 for radioactivity:

a~

 24~7 (petition)

b~

 44~8for Well #1

c0

 36~2and 49~5for Well #2 (Rec~Att, B~1)

3.

 Examination of the record concerning the accuracy

 problem

(City of Ninonk, PCB 8O~l36)reveals involvement

 of radio-~

chemical composition, storage time period

 from

 drying

to

assay, and fluctuations

 in barometric pressure

during

st~ragetime~ These factors lead me to believe

the accuracy

problem is most probably caused by the formation

and adsorp-~

tion of radon,

 a gaseous element produced

 by radioactive

decay of radium~ Since Rule 304 C 1(b) excludes

 radon and

uranium activity from gross alpha emissions,

the

reported

results

 might well be

too

 highs

 It was

stated

that

the

theoretical overestimation can be up to

 four times the

proper

 amounts

40—353

—2—

4.

 Assuming that the high results given include

the

maximum

error of four times, it then follows that

 the alpha activity

is

 primarily the result of

 a high radium

 content.

 Because

of radium’s high relative biological

effectiveness

 (BEE)

Rule 304 C 1(a) states that activity caused

 by radium -266

and

 radium -228 shall not exceed

5

 pCi/l;

and

5.

 Rule 309

 C 1(a) (1)

 states that monitoring

 requirements for

radium

 ~22~and radium —228 may be provided

by gross alpha

particic activity if such activity does not

 exceed

 5 pCi/l

at

 confidence of ninety—five percent.

Respectfully

 submitted,

I,

Christan L. Noffett, Clerk of the Illinois Pollution

Control

Board,

hereby certify that the above Concurring Opinion

 was filed

on the

 day of

 1981.

(C ~L~~j1

~HHS~L~M5T~

 Clerk

Illinois Pollutio

~

 ntrol Board

40—354