SRB Licensing Infractions,
Backgrounder
In March 1994, SRB Technologies Inc. in the United
States began shipping large numbers of used tritium-filled lights from
nuclear weapons facilities at Hanford, Washington and Oak Ridge, Tennessee
to its Canadian subsidiary in Pembroke, Ontario.
Used lights were also shipped from Saunders-Roe, U.K. SRB Technologies
(Canada) Inc. then began reclamation operations, which involved crushing
the lights and reclaiming a portion of the tritium inside them for manufacture
of tritium lights.
SRB did not notify Canadian authorities about
these shipments or reclamation activities. They went undetected until March
1995, when an AECB inspector discovered large numbers of undocumented drums
and trays of used lights during a license compliance check. He noted that
SRB could be deemed as operating a waste facility, and he recommended it
"be directed to cease operation of the Tritium Reclamation Plant,
until a formal assessment relating to all aspects of operation can be conducted."
The March 1995 investigation also revealed widespread contamination in
excess of license criteria.
Despite the findings of this March 1995 investigation,
staff at the AECB took no steps to stop the unauthorized tritium imports,
which continued until October 1995. Although AECB staff did bring SRB's
contamination problems to the attention of the Board in an October 1995
memo, they stated that "licensee has been prompt in addressing all
areas of deficiency. The memo concludes that
"Board staff expect to be in a position to make a firm recommendation
for renewal of the radioisotope license for an additional two years at
the December 7, 1995 Board meeting."
Another AECB staff investigation in early November
1995 revealed continuing serious contamination problems. This prompted
a November 16 meeting between AECB staff and SRB senior management from
the United States and the United Kingdom.
Present were Mike Taylor (Director, Material Regulation Division), Robert
Chamberlain (Senior License Assessment Officer), and inspectors Dave Scott
and Doug McNab for AECB; Brian Pullen (President, SRB Technologies
Inc., U.S.), T. Bartlett (Sales Director, Saunders-Roe,
U.K.) and B. Earl (Director of SRB's U.K. tritium facility) represented
SRB. AECB staff warned they would recommend that the Board not grant an
extension of SRB's operating license after its December 31, 1995 expiry.
On November 21, AECB staff sent a revised memo
to the Board. It concluded that "all licensing issues have been satisfactorily
resolved by the licensee with the exception of widespread tritium contamination.
The memo dismissed
concerns raised by the public about environmental
releases of tritium: "Licensee's current Environmental Monitoring
Program document lacks sufficient detail in some areas and will require
further revision. Nevertheless, Board staff is of the view that this does
not present an impediment to license renewal."
At its December 7, 1995 meeting, the Control
Board decided not to renew SRB's operating license, giving SRB a restricted
license that allowed only storage of tritium on site. This could have meant
that SRB would have to cease its Canadian operations when its license expired
on December 31. Although AECB staff informed Brian Pullen (President, SRB
Technologies Inc., in the U.S.) the next day of this decision, they told
him that the Board might be prepared to revisit it before its next meeting.
Ian Wills, Managing Director for SRB Technologies
(Canada) Inc., left the company not long after this meeting. On December
5, 1995, Wills sent AECB staff a letter alleging that the U.S.-dominated
board of SRB Technologies
(Canada) Inc. had forced him to take actions
that hindered safe operations of the Pembroke facility. He maintained that
SRB's U.S. operations had shipped tritium lights for reclamation to Pembroke
in September and October 1995 despite his warning that the facility had
already exceeded its license maximum of 300,000 curies. He also alleged
that he was pressured to run the reclamation
plant at full speed without regard to permissible environmental releases
of tritium, and that contamination problems were linked to these reclamation
activities. Wills also questioned the legal status of the corporation and
its Board of Directors.
Brian Pullen, President of SRB Technologies Inc.
in the U.S., met with AECB staff on December 13, 1995 to discuss Wills,
allegations. He asserted that at no time had the legal limit of tritium
ever been exceeded. But the next day, he faxed a letter to AECB staff saying
that a Mr. Lee Leonard, formerly of the U.S. Department of Energy, would
be conducting an investigation "to determine the inventory levels
of product currently held". And on December 19, 1995 he faxed a letter
showing that the current total tritium inventory of used tubes, at 385,000
curies, was considerably in excess of the maximum storage
limit in SRB's license. Pullen proposed a temporary increase in SRB's possession
limits to cover the excess.
The next day, David Wilson, a lawyer with Osler,
Hoskin and Harcourt, asked AECB Secretary General J.G. McManus to give
SRB a six-month operating license. Wilson warned that a decision against
SRB could result in layoff of 24 employees in Pembroke, "as well as
irreparable financial losses and possibly permanent harm to the Company's
customer base." He adds that SRB/UK is dependent on product shipped
from the Pembroke plant, and that light fixtures manufactured by SRB "are
urgently required by the U.K. Ministry of Defence for the peace mission
in Bosnia".
Wilson assigned the blame for the excess tritium
inventory to former manager Ian Wills, claiming that SRB corporate management
was "deceived by the discrepancies and inaccuracies in the inventory
records prepared by the previous local management". He said that SRB
had been advised by AECB staff on several occasions that "temporarily
increasing the possession limit should be relatively straightforward as
a licensing matter". He expressed his preference for the 6-month extension
but also offered to "temporarily divert the excess amount to another
facility", suggesting the Chalk River
Laboratories of Atomic Energy of Canada, Ltd.
(AECL).
In the meantime, AECB staff made several visits
to Pembroke to assist SRB in dealing with its contamination problems. On
December 18, Mike Taylor and Robert Walker (Director, Commercial Licensing
Division) visited SRB for a "close-out meeting" and plant tour,
accompanied by Pembroke mayor Les Scott. A memo dated December 20 said
they were "favorably impressed by the recently introduced contamination
control measures, the openness of the new management and of the members
of staff."
This set the stage for an extraordinary meeting
of the Board on December 22, 1995. At this special meeting, the Board granted
a 1-month extension of SRB's operating license to January 25, 1996. In
extending SRB's operatinglicense, the Board overruled a request by AECB
staff, that staff be granted authority to reinstate SRB's operating license
at their own discretion.
Later that day, Mike Taylor faxed a letter to
Brian Pullen requesting a plan to deal with the short term reduction of
SRB's tritium inventory in time for the next regular Board meeting of January
26, 1996. He advised Pullen that failure to resolve this issue could result
in loss of SRB,s operating license. In the ensuing month, SRB's new Canadian
management worked out a temporary storage
arrangement with AECL. The Board subsequently granted SRB a 2-year extension
of its license.
In the period of October 1995 to January 1996,
AECB staff highlighted tritium contamination inside the Pembroke facility
and SRB's excess tritium inventory as the key issues for the Board in deciding
whether to renewing SRB's operating license. But the main focus of public
concern has always been the public health implications of tritium released
by SRB to the local
environment. Both SRB and AECB were aware that
snow samples taken from outside the facility in December 1995 were found
to be heavily contaminated with tritium. Tritium levels ranged from thousands
to millions of Becquerels per liter, compared to a natural background of
around 5 Becquerels per liter.
Since January 1996, environmental monitoring
issues have repeatedly been discussed by AECB staff and SRB, with a final
resolution still pending. SRB delayed in providing maps and diagrams that
accurately depicted its facility in relation to nearby businesses and residences.
One point of contention has been the potential for locally grown fruit,
vegetables, and milk to be contaminated with
tritium. SRB has steadfastly refused to monitor locally grown produce,
maintaining that there are no home gardens in the local area. On several
occasions, most recently in June 1997, SRB has released levels of tritium
through its stacks in excess of levels that trigger an internal investigation
and a report to the AECB. None of these incidents was ever brought to the Board's attention.
Despite this history of problems at SRB, Robert
Walker notifed SRB in July 1997 that the AECB would "extend for two
years the valid period of expiring radioisotope licenses that meet certain
criteria, thereby deferring the usual pre-renewal assessment". He
added that "To ensure that health and safety are not compromised,
we will not extend any licences where our records
indicate an unfavourable compliance history, high occupational exposures,
occurrence of incidents or any other factors which might lead us to believe
that a licensee's operations needs to be examined more closely". He
told SRB that "your license is one of those that meets the extension
criteria above", and informed them that no renewal application forms
would be required, merely a response from SRB indicating their agreement
to proceed in this fashion.
At an informal meeting prior to the July 1998
AECB meeting in Pembroke, CCRC members raised the issue of why SRB was
granted an extension of its license in 1997 without an opportunity for
public review with members of the Board and senior AECB staff.
Epilogue: SRB has been granted an extension of
their license to Dec./2000 after which the operation will become a Class
1 nuclear establishment.
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