Emissions of tritium from SRB Technologies (Canada) Ltd., a local company licensed by the CNSC to manufacture self-luminous light sources, 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". A family restaurant, a brew your own beer store, a community skating arena, and residences are located within 250 meters of the stack.
As far as we can tell (after many years of research), tritium releases here are on a scale unprecedented anywhere else in the world. Tritium is a persistent, toxic radionuclide with a half life of 12.3 years. Local wells are contaminated at roughly 900 times background levels and have shown an increasing trend in recent months (January 2004: 1495 Bq/l; August 2004: 1762 Bq/l.) Vegetables from neighbouring gardens are contaminated at roughly 3000 times background levels. Air is contaminated, snow is contaminated, pool water is contaminated, and urine of local residents is contaminated.
For fifteen years we have been trying to work within the nuclear regulatory system to get this problem addressed. We have spent many hours of personal time, have attended meetings and licensing hearings, and have 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 this history indicates problems with the way the CNSC is carrying out its legal mandate (see Annex I). We suggest that examining SRB Technologies (Canada) Ltd. as a case study could help make your organization more effective and efficient as a regulator.
We therefore respectfully request your personal involvement in a review of this matter. Specific issues we would like to see addressed are:
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 35-fold less than those calculated and validated by the CNSC itself, yet regulatory action is based on the licensee's modeled 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 to our knowledge received final CNSC approval
despite this being a specific condition of the current license.
4) Establishing allowable limits for each and every radioactive
substance released by the nuclear industry is problematic. There
are often multiple sources of exposure. Hundreds of different
radionuclides are released to the environment, with widely varying
half lives. Residents of Pembroke and neighbouring communities
are exposed to significant radioactive emissions and corresponding
radiation doses from the Chalk River Laboratories of Atomic Energy
of Canada, Ltd., as well as from SRB Technologies. Yet, current
regulatory procedures do not adequately address cumulative doses
from multiple sources.
5) Section 6 of the Radiation Protection Regulations allows the CNSC to set action levels to maintain radiation doses "as low as reasonably achievable." Action levels represent a fraction of the maximum public dose (e.g., 5% of the 1 milliSievert dose, or 50 microSieverts). This action level is intended to trigger corrective action by the licensee. The CNSC's calculated doses from SRBT's emissions have been validated by the CNSC's own monitoring programs, and by independent monitoring. SRBT's modeled doses have conclusively been shown to be incorrect. Yet the CNSC still accepts SRBT's modeled doses as a threshold for regulatory action. The CNSC thereby fails to require that the licensee take corrective action to reduce its emissions.
Our group has recently been in contact with the Auditor General's office regarding this matter. We wish to inform you that you will likely hear from them in the near future.
We would like to meet with you to discuss these matters. We will be contacting your office to find a time that works for you.
Yours sincerely,
Kelly O'Grady Lynn Jones Ole Hendrickson
lead@nrtco.net ljones@nrtco.net ole@nrtco.net
Annex I
Review of the regulation of radioactive gas emissions from SRB Technologies (Canada) Ltd. (SRBT) by the Canadian Nuclear Safety Commission (CNSC)
2. The CNSC licenses SRB Technologies (Canada) Ltd. of Pembroke, Ontario (http://www.betalight.com) to manufacture self-luminous lighting devices filled with tritium gas, a radioactive form of hydrogen.
3. Most of SRBT's tritium supply comes from the Darlington Tritium Recovery Facility, operated by Ontario Power Generation.
4. 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 manufacturing processes. SRBT does not report on this activity and it is not described in its CNSC manufacturing license.
5. The CNSC, SRBT, AECL, and 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."
6. In summer 2003 SRBT 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.
7. These results were omitted from SRBT's 2003 Annual Compliance Report. Appendix A of the compliance report, entitled "Environment Monitoring Program", instead provided values for these same three vegetables in the range of 35 to 180 Bq/L.
8. A March 4, 2004 letter from CNSC project officer Ann Erdman to Pembroke resident and CCRC member Kelly O'Grady estimated 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 added that "doses from contributions from other exposure pathways [e.g., air inhalation and drinking water consumption] would be in addition to this estimated dose".
9. A CNSC staff assessment (File No. 42-1-3-0), based on CNSC's own passive air sampling of tritium done near SRBT from May 2002 to April 2003, estimated total yearly 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, rather than the 27 uSv dose calculated by the CNSC in March 2004. It also included a 3 uSv drinking water dose based on well water contaminated with tritium at 230 Bq/L. However, new evidence shows that well water contamination exceeds 1700 Bq/L.
14. In allowing SRBT to grossly under-calculate the doses caused by its emissions, CNSC is failing to require the company to take measures to reduce these emissions.
15. The CNSC has not made SRBT recalculate its Derived Release Limits (used by SRBT to model public doses), nor has it made its own recalculation. Derived Release Limits are a key regulatory instrument governing SRBT's radioactive gas releases.
16. CNSC is not effectively implementing provisions
of the Nuclear Safety and Control Act intended to limit
risks to health and safety of persons and the environment associated
with production, possession and use of nuclear substances.