March 27, 1995
Dear Dr. Bishop:
We recently received a copy of BMD 95-32, concerning an initial consideration of renewal of the radioisotope license for S.R.B. Technologies (Canada) Inc. We are requesting that you not grant a renewal of the radioisotope license for S.R.B. Technologies (Canada) Inc. unless specific environmental monitoring conditions are included in the license. Our reasons for this request are detailed in this letter.
When the original radioisotope license was granted to S.R.B. Technologies in December 1990, the licensee was permitted to release tritium at 0.2% of the DRL for the site. During licensing hearings, our group made a submission expressing concern about environmental releases of tritium. We received a promise from the licensee that our group would be provided with tritium monitoring data on a regular basis. That promise has not been fulfilled.
In June 1994 the licensee proposed to increase tritium releases to 1% of the DRL, and this request was granted in September 1994. BMD 95-32 indicates that the average tritium release for the entire 1994 calendar year was 0.25% of DRL. We are concerned that the licensee may have already been exceeding the 0.2% release level at the time the increase was approved. This poor performance underscores the need for close monitoring of environmental tritium levels near the facility.
A letter from a member of the public opposing the increase in the release limit raised the issue of excess cancer deaths in the area. BMD 95-32 dismisses this concern, citing unpublished analyses by AECB staff and Ontario Cancer Treatment and Research Foundation that concluded that cancer levels in the area were not elevated. We challenge this conclusion, and request that you direct AECB to provide our group with a copy of these findings. We are enclosing a copy of the Renfrew County Health Status Report, Issue #3, December 1994, which shows that potential years of life lost from cancer is significantly elevated in Renfrew County. We are not claiming that this phenomenon is related to tritium releases from S.R.B. Technologies (Canada) Inc., but we are concerned that AECB staff may not be providing the Board with technically sound analyses in response to public concerns.
BMD 95-32 also states that analyses of environmental samples "have not shown levels of tritium which exceed 5% of the Health Canada's Drinking Water Standards". We are concerned by the implication that some environmental samples may be showing tritium levels approaching 5% of the Drinking Water Standards. We request that the licensee be directed to collect samples on no less than a weekly basis, given that the current sampling interval of two months could fail to detect elevated tritium levels persisting for considerable time periods between samplings. We also would like information on sample locations so that we can be assured that these are representative of the variety of local environmental conditions. Given that the licensee has not honoured a promise to provide our group with these environmental data, we request that you direct AECB staff to ensure that this is done.
BMD 95-32 states that "it is anticipated that during the license period, improvements will be made to the [environmental monitoring] program in terms of the location, types and frequency of samples". This demonstrates a weak commitment to protecting public health and safety and addressing public concerns. We find it unacceptable that NO environmental monitoring program is currently described in the license conditions proposed by AECB staff.
The licensee's facility is located in close proximity to other businesses and workplaces. There is a nearby open area which is frequently used for recreational activities by local residents. We urge you to protect the health and safety of the citizens of Pembroke and Renfrew County by including a strong and credible environmental monitoring program as a condition of any license granted to S.R.B. Technologies (Canada) Inc., and by routinely providing the public with the results of this program.
We appreciate your attention to our concerns, and look forward to receiving your reply.
Sincerely yours,
Ole Hendrickson