DEPUTATION: WHEN's position on Pickering B

In the fall of 2008, Dorothy Goldin Rosenberg MES PhD presented a deputation on behalf of the Women's Healthy Environments Network (WHEN) to the Canadian Nuclear Safety Commission (CNSC) on the proposed life extension of Pickering B nuclear reactor.

Summary of WHEN’s deputation to the Canadian Nuclear Safety Commission (CNSC)

The proximity of the Pickering nuclear stations to Toronto and the routine discharges of radioactive tritium into the drinking water of millions of Ontarians are of major concern to WHEN.

Just 30 km from downtown Toronto, the Pickering nuclear station is closer than any other nuclear reactor in the world to a major population centre. For this reason, we believe the Canadian Nuclear Safety Nuclear Commission (CNSC) would not allow a new plant to be built at Pickering today.

The CNSC website declares that "the CNSC considers it crucial to preserve public confidence and trust in the fairness of the regulatory decision-making process." There is serious concern about whether nuclear reactors should be allowed to operate so near to residential communities. For reasons we outline below, radioactive releases should never be allowed into the environment. The Pickering B reactor should be safely decommissioned, as soon as possible and at the latest by 2014 (the end of its operational life), to protect the environment and health and safety of living systems on which we depend.

Along with many others, WHEN maintains that the environmental review on the proposed life-extension of Pickering B nuclear station systematically excludes and misrepresents the significant environmental impacts resulting from the continued operation of the Pickering B nuclear station. Thus, we feel the environmental review must be rejected.

Tritium

Under our previous name, the Women's Network on Health and the Environment (WNH&E), WHEN worked with many other groups to support the ACES Report (released 1994-1995) calling for the reduction and eventual elimination of radioactive Tritium emissions from nuclear facilities in Ontario. More recently WHEN has been part of the Toronto Cancer Prevention Occupational and Environmental Working Group which initiated the discussions with Toronto Public Health. Information regarding and regulation of the carcinogen, mutagen and teratogen Tritium should fit in the consideration of proposed legislation on Community Right to Know and Toxic Use Reduction currently under deliberation in several jurisdictions.

In March 2008, WHEN’s presentation to the Ontario Drinking Water Advisory Council (ODWAC) elaborated on these points referring to other reports and studies highlighting the need to protect in particular, women, the developing fetus, growing children and young girls in puberty from exposures to tritium at any dose ideally. For example, Biological Effects of Ionizing Radiation (BEIR) Vll reconfirmed that there is no safe level of exposure to radiation and that low levels can cause cancer. (The EU is well informed of the more effective impacts of low routine doses of ionizing radiation according to research evidence by Dr. Abram Petkau, 1999.) Even exposures to background radiation cause some cancers. Additional exposure causes additional risk. The BEIR Vll report also found that the risk of cancer was greater to women and children, the younger the children, the greater the risk, females being at greater risk.

For these and other reasons, the International Joint Commission (IJC) 7th Biennial Report on the Great Lakes recommended that radionuclides with a half life of greater that 6 months be included in the list of persistent toxic substances, and that governments work toward virtual elimination of these substances under the Great Lakes Water Quality Agreement, and that strategies for virtual elimination of these pollutants from waste streams be implemented. Radioactive Waste

There is approximately 20,000 tonnes of high-level radioactive waste stored at the Pickering nuclear station. Extending the life of the Pickering B nuclear station will create approximately 10,000 additional tones. These radioactive wastes must be isolated from the environment and humans for a million years. Although the nuclear industry-controlled Nuclear Waste Management Agency is searching for a community willing to house these wastes, there is no guarantee such a community will ever be found.

Recommendation: The CNSC should not approve the life-extension of Pickering B before a long-term plan for the management of the radioactive wastes produced by Pickering is established. Terrorism

The Pickering nuclear station was not designed to withstand terrorist attacks. In the post-September 11 world, the Pickering B reactor design would not be approved because of its vulnerabilities to terrorist attacks. Pickering B’s multi-unit design and shared systems make it particularly vulnerable to catastrophic accidents in the event of a terrorist attack.

Although the design of new nuclear stations in Canada will be required to be robust enough to resist certain terrorist attacks, the CNSC has allowed existing nuclear stations to forgo expensive design changes to adapt to the post-September 11 reality. Furthermore, while requiring environmental reviews on new reactor designs that assess the environmental impacts of terrorist attacks, the CNSC has specifically excluded such an analysis from the present environmental review. The current environmental assessment, therefore, is inadequate.

Recommendations: 1. All environmental assessments on the proposed life-extension of ageing nuclear stations, including the present review, should include a review of the environmental impacts of terrorist events. 2. Given the design vulnerabilities of the Pickering B station, the life extension of the station should not be approved. 3. Existing radioactive waste storage facilities should be made resistant to terrorist attack.

Accidents and Evacuation

The environmental assessment identifies a nuclear accident involving the release of radiation and triggering evacuations or sheltering in a 10 km area around Pickering B as ‘credible’. That is, according to the CNSC’s own guidelines this accident has a reasonable probability of occurring. Such an accident would cause chaos across Toronto. The siting of a nuclear station so close to such a dense population centre poses an unacceptable risk to the City of Toronto.

Recommendation: The CNSC should not approve the life-extension of the Pickering B nuclear station. The station should be shut down at the end of its operational life in 2014. Slightly Enriched Uranium

The CANDU design shares an inherent design flaw with the Chernobyl RBMK reactor design that significantly weakens its ability to control and cool the nuclear reaction in accident situations. Specifically, the reactor core design of both the CANDU and Chernobyl reactors exhibit “positive reactivity”; that is, the reactor power has a tendency to increase, potentially in an explosive pulse. Because of the inherent hazard of positive reactivity of CANDU reactors, Ontario’s nuclear stations would be deemed too hazardous to licence under modern safety requirements.

Bruce Power is currently proposing to change from natural uranium fuel to slightly enriched uranium, otherwise known as Low Void Reactivity Fuel (LVRF), to mitigate the hazards of positive reactivity. The use of enriched uranium, however, presents new environmental hazards in the nuclear fuel chain in Canada, such as out of reactor criticality.

The environmental assessment on the life-extension of Pickering B has not addressed the possibility of using enriched uranium to mitigate the hazards of positive reactivity. The current assessment is, therefore, inadequate, pending a review of the environmental impacts of using of slightly enriched uranium.

Recommendation:  Given that modern licensing requirements would not permit the licensing of reactors with positive reactivity, the CNSC should not approve the life-extension of Pickering B. In conclusion, the CNSC would not allow a new plant to be built at Pickering today. We believe, then, that the CNSC has a duty to order the shut down of Pickering B when it reaches the end of its operational life in 2014.REFERENCESInternational Joint Commission (IJC) 7th Biennial Report on the Great Lakes, Recommendation 12 to Federal, Provincial/State Governments, February, 1994.

DEPUTATION: WHEN's position on Tritium and its Risk to Our Drinking Water

In light of the plans for nuclear power expansion in Ontario and elsewhere, many millions of our tax dollars are to be spent to renew the nuclear industry with very little attention to the impacts of ionizing radiation, namely tritium (and other radionuclides) affecting the health of millions of citizens and the ecosystem.- WHEN's deputation to the Ontario Drinking Water Advisory Council (ODWAC) on Tritium, March 2008.

In the spring of 2008, WHEN’s Education and Outreach Coordinator, Dorothy Goldin Rosenberg, presented a deputation on behalf of the Women's Healthy Environments Network (WHEN) to the Ontario Drinking Water Advisory Council (ODWAC) on Tritium. Tritium is a known carcinogen, mutagen and teratogen (it crosses the placental barrier to cause harm) which is routinely released from CANDU reactor operations into the drinking water of millions of Ontarians and others.

In light of the plans for nuclear power expansion in Ontario and elsewhere, many millions of our tax dollars are to be spent to renew the nuclear industry with very little attention to the impacts of ionizing radiation, namely tritium (and other radionuclides) affecting the health of millions of citizens and the ecosystem. Our presentation to ODWAC elaborated on these points, referring to reports and studies that highlighted the need to protect, in particular, women, the developing fetus, growing children and young girls in puberty, from exposures to tritium, ideally at ANY dose.

The study, Environmental and Occupational Causes of Cancer: A Review of Recent Scientific Literature, [i] was cited in reference to the cancer risks to the general public from tritium. (This study lists several cancers and the chemicals/radiation they are related to [p. 10]). Of particular note in relation to tritium is the relationship of ionizing radiation to bladder, bone, brain, breast, colon, leukemia, liver, lung, multiple myeloma, nasal and nasopharynx, stomach and thyroid cancers.

It is now known that there is no safe dose of radiation and even the smallest dose can cause cancer and other health effects [ii] The government of Ontario should strive to eliminate risks to the environment and to the human health of the citizens of Ontario.

WHEN's RECOMMENDATIONS TO THE ODWAC

• In light of people’s exposure to the cumulative effects of numerous of chemicals and radionuclides and the synergies they combine to produce, WHEN recommends more stringent standards immediately. Lower limits are achievable. And it is sensible, at least for now, to use an approach similar to that used for chemicals to determine "acceptable" levels of risk, an approach called for by the Advisory Committee on Environmental Standards (ACES) in 1994. Unfortunately there is now much catching up to do, as the current Ontario Drinking Water Objective for Tritium of 7,000 Becquerel per litre (Bq/L) is considerably higher than ACES’s recommendations then of immediate adoption of a 100 Bq/L standard, reduced to 20 Bq/L within five years, were ignored by the government of the day due to pressure from the nuclear industry and has remained ignored to date.

• Ontario needs to join other leading jurisdictions in the world which have more stringent standards - the EU Tritium in water Standard is 100 Bq/L, California is at 15 Bq/L and Colorado, 18 Bq/L. Moreover, it is of great significance that Ontario Power Generation (OPG) has stated in their ISO 140001 QA documents that 100Bq/l is now an achievable standard for Tritium in water and therefore the reduction of 7,000 Bq/L to the federally proposed 3,000 Bq/L should not be acceptable. Therefore the ACES recommendation of 100 Bq/L to 20Bq/L within five years is the largest standard we can agree to at this time.

• Because of the now widely available evidence presented on health impacts, WHEN recommended that ODWAC urge the Ontario government to adopt the Precautionary Principle in its recommendations to them. If it is to err at all, the committee should err on the side of caution when assessing the hazards of Tritium emissions and should, at the start, reiterate the recommendations of the Advisory Council on Environmental Standards (ACES) on Tritium. Thus, WHEN recommends that ODWAC advocate a decrease in tritium standards from the current 7,000 Bq/L to 100 Bq/L and then to 20 Bq/L within five years as recommended by ACES, with the goal of zero discharge in ten years.

• WHEN endorsed the energy framework, principles and recommendations of the letter by Dr. David McKeown, MDCM, MHSc, FRCPC, Toronto Medial Officer of Health to Premier Dalton McGuinty regarding the Ontario Power Authority’s Supply Mix [iii]. Dr. McKeown calls for a sustainable energy strategy for the province composed of a combination of measures, in the following order of priority: demand management (energy efficiency and conservation) approaches and supply from low-impact ecologically sustainable renewable sources rather than by nuclear energy.”

• WHEN concurred with recommendations contained in the Pembina/CELA Report [iv], that nuclear power plants be phased out by 2020 stopping all such releases.

Reference

[i]Richard Clapp, Genevieve Howe, Molly Jacobs. Environmental and Occupational Causes of Cancer: A Review of Recent Scientific Literature Boston University, School of Public Health and Environmental Health Initiative, University of Massachusetts, Lowell, September, 2005.

[ii]Biological Effects of Ionizing Radiation Vll -- BEIR VllE National Academy of Sciences, 2005, http://www.nuclearactive.org/news/070605.html

[iii]Dr. David McKeown, MDCM, MHSc, FRCPCOntario Power Authority's Supply Mix: Advice Report December 2005 EBR #PO05E0001; Feb 3, 2006

[iii]Pembina Institute and Centre for Environmental Law and Policy (CELA) Power for the Future Towards a Sustainable Electricity System for Ontario www.cela.ca, www.pembina.org