Concerned Citizens of Renfrew County and Area

P.O. Box 981, Pembroke, Ontario K8A 7M5

Tel. : (613) 735-4876 Fax: (613) 735-6444

 

August 30, 1999

 

Dr. Agnes Bishop

Atomic Energy Control Board (AECB)

280 Slater Street, P.O. Box 1046

Ottawa, ON K1P 5S9

 

Dear Dr. Bishop:

 

CCRC has had longstanding concerns about tritium emissions from SRB Technologies (Canada) Inc. in Pembroke. Over the course of the last year we have had the opportunity to peruse approximately 1000 pages of correspondence between your Board staff and SRB management pertaining to licensing matters. We have also had conversations with SRB's Radiation Protection Officer and the Medical Officer of Health for Renfrew County, Dr. Michael Corriveau., who shared with our group information received from Dr. Mary Measures of your staff. Our concerns have increased greatly as a result of new information gained from these sources.

 

Among other things, we have learned that

 

SRB has for some year been operating a tritium reclamation facility;

SRB's tritium emissions increased from 197 TBq (including 26 TBq of HTO) in 1994 to 970 TBq (including 103 TBq of HTO) in 1997;

SRB management resisted Board staff recommendations to finalize an environmental monitoring program, and there is still no approved monitoring plan in place;

The residence address used by SRB for calculating the radiation dose to the maximally exposed member of the general public is directly upwind of the facility; and

SRB did not consider ingestion of organically-bound tritium in calculating its Derived Release Limits, and claimed that nearby residents were not growing food for home consumption.

 

We have recently received reports (attached) on vegetation samples that were analyzed for tritium content by the Environmental Isotope Laboratory at the University of Waterloo, and by Becquerel Laboratories in Missisauga, Ontario. A rhubarb sample collected from a garden 800 m downwind from SRB had a tritium concentration of 2000 Bq/L free water, and a control sample from a distant location in Renfrew County had a concentration of 2 Bq/L. A sample of aspen leaves collected about 50 m behind the plant had a tritium concentration of 1890 Bq/L free water. The latter sample had a larger concentration of tritium than any of the aspen leaf samples analyzed by Brown (1978) in his study of environmental tritium in trees in the vicinity of the Chalk River Nuclear Laboratories.

 

We believe this level of environmental contamination is unacceptable. We understand that there is a pollution control device that can reduce airborne tritium emissions to near zero. We have written to SRB's management asking that they install such a device (your copy of this letter is enclosed). We hope that they will do this voluntarily, but if they do not, we will be looking to you, as the regulator, to eliminate tritium emissions as a condition of re-licensing when SRB's license comes up for renewal in December of this year.

 

In addition, we urgently request that a thorough, peer-reviewed assessment be conducted to detail the degree of tritium contamination in the vicinity of SRB Technologies (Canada) Inc. and that it be followed up with a thorough, ongoing, and impartial environmental monitoring program. We would be pleased to be part of an oversight committee for this process.

 

We look forward to hearing from you.

 

Sincerely yours,

 

 

Lynn Jones, President

 

cc: Robert Chamberlain, Senior Licensing Officer, AECB

Hector Clouthier, Member of Parliament, Renfrew-Nipissing-Pembroke

Sean Conway, Member of Provincial Parliament, Renfrew-Nipissing-Pembroke

Paul Curtis, Warden, Renfrew County

Les Scott, Mayor, City of Pembroke

Dr. Michael Corriveau, Medical Officer of Health, Renfrew County and District

Attach. (2)

Encl.

 

Reference: Brown, R.M. 1978. Environmental tritium in trees. International Atomic Energy Agency IAEA-SM-232/44. Pages 405-418.

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