Presentation at AECB meeting of October 24, 1996

Concerned Citizens of Renfrew County

The group I represent, Concerned Citizens of Renfrew County, is grateful for the opportunity to make a short presentation to the Board related to the renewal of the license for AECL's Chalk River Laboratories.

Our group, and most likely the community at large, has one general concern with operations at AECL: our health, and the health of our children and subsequent generations. We see our health threatened by two interrelated issues:

- the management of radioactive wastes on the AECL site;

- and releases of radioactive substances to air and water.

Radioactive waste management

As noted by Mayor John Murphy of Deep River, AECL-Chalk River is Canada's only publicly available radioactive waste facility, and it receives commercial wastes on a weekly basis. Yet there is no disposal plan for these wastes, or for the wastes generated by AECL itself. Our group made a strong plea to the AECB during the last license hearings to require an overall decommissioning plan for wastes on the AECL property, and we are pleased that others are echoing our concerns. But we do not feel that the proposed license is adequate and that the AECB is properly exercising its regulatory authority in this regard.

Wastes are said to be "stored" at the AECL site, but it is likely that only a small fraction of them will ever be reused. In fact, AECL has been conducting radioactive waste disposal on its Chalk River property for decades. Under the Atomic Energy Control Regulations, radioactive waste disposal facilities must either have individual licenses, or be regulated under a general site license. Yet the only provision in the proposed license I can find regarding the Waste Management Areas is in condition 24, which requires that AECL keep records on radioactive substances placed into and removed from them.

As a specific example, the 1995 AECB Annual Staff Report on Chalk River Laboratories cites as a significant instance of non-compliance with the license, the placement of 37 boxes of tritium exit signs in Waste Management Area C. Yet this finding of non-compliance appears to be based upon "the radiological acceptance criteria for packages", and not the total inventory of wastes in Area C, even though the tritium inventory of Area C was significantly increased as a result.

I do not fell that there is a simple solution to the radioactive waste problems at AECL. I believe that a proper review of the possibility of licensing the ongoing disposal activities would lead to the conclusion that the property is not suitable for a permanent disposal facility. owing to its unfavourable geological and hydrological characteristics, together with its proximity to a major drinking water resource. For example, there is a large tritium plume exiting Area C, which as been partly remediated by installation of a plastic/sand infiltration barrier. Other Waste Management Areas at AECL require mobile groundwater treatment plants to reduce subsurface contamination. The need for such remedial measures argues strongly against licensing any disposal facilities on the property. Yet the status quo, which could be characterized as unregulated radioactive waste dumping, is also clearly unacceptable.

As Mayor Murphy point out in his comments on the license renewal, this regulatory void means that waste generators are not paying realistic rates for sending wastes to Chalk River. The danger is that taxpayers will ultimately bear the disposal costs for the nuclear industry, as has already come to pass with the proposal to ship Port Hope refinery wastes to Chalk River.

Our ultimate fear is that the Chalk River site will simply be abandoned, and that the chronic low-level radioactive contamination of the Ottawa River will become a permanent hazard to the health of all future Canadians who might choose to drink, swim in, or fish in its water. As regulators of the nuclear industry, it is your responsibility to ensure that this does not happen.

Releases of radiation

J.F. Palmer's 1981 document, "Derived release limits (DRL's) for airborne and liquid effluents from the Chalk River Laboratories during normal operations", sets upper bounds for releases of radiation. I do not believe that these DRL's adequately protect the health of Renfrew County residents, or the employees of AECL-Chalk-River.

Airborne release limits were calculated by Palmer based on individual doses at the upriver property boundary, six kilometres from the major point of release, the reactor stack. This tall stack follows a "principle" once used to justify dispersing sulphur dioxide away from nickel smelters: "dilution is the solution to pollution". Thus, a half-billion fold average dilution factor is built into the calculation of the DRL's. This has the curious effect that total "off-site" emissions are permitted at much higher levels that "on-site" emissions. This would arguably be acceptable of stack plumes were indeed rapidly and perfectly dispersed by the half-billion factor before leaving the plant boundary. But this is not the case, and a member of the public could receive a relatively high radiation dose, higher than those permitted for workers, simply by having the bad luck to be immersed in the stack plume.

The current DRL's are not conservative in their protection of public health for two other reasons, both discussed in Palmer's 1981 document:

- radionuclides persist in the environment, and the true dose delivered in any one year is the sum of doses arising from that year's releases and all previous years' releases, corrected for radioactive decay and natural removal processes; and

- limits on total population dose, or "collective dose", could be established to limit total health impacts to an acceptable level.

Palmer took the view that "a limit on collective dose is inappropriate", and he declined to take into account the cumulative effect of persistent radionuclides, without justifying these decisions from a public health perspective.

The potential negative health impacts of these decisions, which are built into the regulatory limits for releases of radiation from AECL-Chalk River, are further aggravated by two other considerations. First, the average lifespan of a human being is in excess of 70 years, rather than a single year. Many Renfrew County residents have spent their entire lives exposed to higher radiation levels than they would have experienced had AECL not been in existence.

Second, it is my impression that the DRL's are being interpreted as setting limits for each individual point of release from AECL's various facilities, ignoring the cumulative nature of radiation doses. Thus, in the 1995 Annual Staff Report we see that Appendix B shows releases of noble gases from the reactor stack at 1% of the site DRL, while Appendix C shows argon-41 releases from the NRU reactor, through the reactor stack, at 4.1% of the facility DRL. The only explanation I can find for this discrepancy is that various facilities are treated as independent units with regard to emissions of radionuclides. This raises the question as to whether the AECB will regulate emissions from the two or more new reactors proposed for the Chalk River property on an individual or cumulative basis. If regulation on an individual basis were carried to its logical extreme, there would in effect be no limit on cumulative releases.

Although the foregoing comments apply to airborne releases, it should be noted that waterborne releases appear to be treated in similar fashion: a large dilution factor is applied based on average (not minimum) river flow, build-up of radiation over several years (in sediments, fish, etc.) is ignored, collective dose is ignored, and various release points are treated individually.

I am not an expert on health effects of radiation, and I may be misinterpreting some of the information contained in Palmer (1981). However, I believe that these concerns are of sufficient gravity to warrant a review of the regulatory limits for releases of radiation from AECL's Chalk River facilities by independent public health experts. The current rewriting of these regulatory limits provides an obvious opportunity for such a review.

I would like to thank the board for this opportunity to voice the concerns of our group. We believe that you have an important responsibility to ensure the health and safety of Canadians, present and future. We wish you success in your efforts to carry out this responsibility.