Dear Ms. Fraser
The City of Pembroke, Ontario is heavily contaminated with tritium, a radioactive, carcinogenic and teratogenic form of the element hydrogen to which there is no safe level of exposure. Emissions of tritium by a local manufacturing company here are higher than those from four large power reactors at the Pickering nuclear generating station when it is fully functional. Yet in our case, there is no buffer zone between the point of emission and public areas "next door". In fact there are a family restaurant, a brew your own beer store, a community skating arena, and residences within 250 meters of the stack.
As far as we can tell (after many years of research), tritium releases here are on a scale that is unprecedented anywhere else in the world. Contamination is accumulating as tritium is a persistent, toxic chemical with a half life of 12.3 years. Wells are showing increasing contamination to up to 800 times background levels. Vegetables from neighbouring gardens are contaminated at 3000 times background levels. The air is contaminated, the snow is contaminated, pool water is contaminated, and the urine of local residents is contaminated.
The federal agency responsible for regulating the company in question is the Canadian Nuclear Safety Commission. For fourteen years we have been trying to work within the nuclear regulatory system to get this problem addressed with very little progress. We have spent many hours of personal time, have attended numerous meetings and written letters too numerous to count. The progress is so slow and the contamination problem so serious, that we are tired of waiting, and would like to request your help.
We believe that there are serious problems with the way in which the CNSC carries out its mandate that make it ineffective and inefficient as a regulator. 0 The specific issues that we would like to see addressed are as follows:
1) The CNSC allows its licensees to calculate and establish their own emission limits. We find this inappropriate. In our situation it quite plainly does not work. The licensee's reported radiation doses to the public are at least 50-fold less than those calculated by the CNSC itself, yet emission limits are based on the licensee's calculated doses (see Annex 1).
2) It is difficult for the public to participate in the regulatory process. Licensing hearings are only held every 5 years. Members of the public are only permitted to intervene at the second of the two hearings late in the decision-making process.
3) License conditions are not enforced and there appear to be no consequences for violations. We have raised this in the matter of the licensee's Quality Assurance Program, for example. It has not been approved despite being a specific license condition.
4) The practice of establishing allowable limits for each and every radioactive substance released by the nuclear industry based on the allowable 1 milliseivert maximum public dose for a member of the public is patently absurd since there are hundreds of different radionuclides and they all persist in the environment.
5) Section 6 of the Radiation Protection Regulations allows the CNSC to set action levels to maintain radiation doses "as low as reasonably achievable". These are generally set a fraction of the maximum public dose (e.g., 5%), and are intended to trigger corrective action by the licensee. However, in our situation, where the licensee's calculated doses are far less than the CNSC's calculated doses, the CNSC still accepts the licensee's doses as a basis for (in)action.
We are attaching additional background information and look forward very much to hearing from you on this matter.
Annex I
Canadian Nuclear Safety Commission regulation of SRB Technologies(Canada) Ltd. (SRBT)
1. The Canadian Nuclear Safety Commission (CNSC) licences SRBT Technologies (Canada) Ltd. (http://www.betalight.com) to manufacture self-luminous lighting devices filled with tritium gas, a radioactive form of hydrogen. Most of SRBT's tritium supply comes from the Darlington Tritium Recovery Facility, operated by Ontario Power Generation.
2. SRBT also imports waste lights, breaks these, and recovers a portion of their tritium content, while venting the remainder through its stacks and sending the radioactive glass wastes to Atomic Energy of Canada Ltd. (AECL). It uses this tritium in its manufacturing processes. It does not report on this activity and it is not mentioned in its CNSC manufacturing license.
3. The CNSC, SRBT, AECL, and Concerned Citizens of Renfrew County (CCRC) have all done tritium monitoring in Pembroke. The issue of tritium contamination generated considerable controversy when the Globe and Mail published a September 28, 1999 article, entitled "The atomic rhubarb of Pembroke". It reported that rhubarb grown near SRBT contained 2000 Bequerels per liter of tritium, "about 1,000 times the radioactive tritium found either in rain water in Ottawa or in a rhubarb sample taken from a garden about 45 kilometres away."
4. SRBT recently measured the tritium content of tomatoes, zucchini, and cucumbers grown in the garden of Mr. Wesley Stuber, 408 Boundary Road. Results, based on analyses by the Ontario Power Generation Health Physics Laboratory, ranged from 4700 Bq/L to 6400 Bq/L.
5. These results are omitted from SRBT's 2003 Annual Compliance Report. Appendix A of the compliance report, entitled "Environment Monitoring Program", instead provides values for these same three vegetables in the range of 35 to 180 Bq/L.
6. A March 4 letter from CNSC project officer Ann Erdman to Pembroke resident and CCRC member Kelly O'Grady estimates the dose to a member of the public from eating vegetables from Mr. Stuber's garden at 27 uSv per year. Ms. Erdman's letter adds that "doses from contributions from other exposure pathways would be in addition to this estimated dose".
7. A CNSC staff assessment (File No. 42-1-3-0), based on passive air sampling of tritium done near SRBT from May 2002 to April 2003, estimated total adult dose at 66 uSv, 49 uSv from inhaling contaminated air. This 66 uSv dose estimate included only a 12 uSv dose from eating vegetables. It also included a 3 uSv dose from drinking well water contaminated with tritium at 230 Bq/L. However, new evidence shows that well water contamination exceeds 1600 Bq/L.
8. Taking account of the CNSC's new estimate of public dose from vegetable consumption, and adjusting the CSNC drinking water dose upwards, the total public dose from SRBT is around 100 uSv.
9. SRBT's 2003 Annual Compliance Report estimates public dose at 1.8uSv.
10. SRBT's estimates, which are more than 50-fold lower than CNSC's estimates, are used by the CNSC to set regulatory limits for the company's emissions of radioactive gases.
10. When SRBT's weekly emissions exceed the equivalent of an annual dose of 25 uSv, its license requires it to conduct an internal investigation. When weekly emissions exceed the equivalent of 50 uSv, the company is required to file a report to the CNSC describing the circumstances and actions to be taken to prevent a recurrence. These are the company's "Action Levels" pursuant to section 6 of the Radiation Protection Regulations under the Nuclear Safety and Control Act.
11. In allowing SRBT to under-report doses caused by its emissions, CNSC is failing to require the company to take measures to reduce these emissions.
12. The CNSC has not made SRBT recalculate its Derived Release Limits, or made its own recalculation. This is the key regulatory instrument governing radioactive gas releases. CNSC is thereby not enforcing provisions of the Nuclear Safety and Control Act intended to limit risks to health and safety of persons and the environment associated with use of nuclear substances.
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