TAP Canada

Here is what the CNSC staff say (source) about groundwater contamination near SRB Technologies:

“The monitoring data collected by SRBT since the last licence renewal continue to be within the range predicted from CNSC staff’s modeling assessment conducted in 2010, as shown in figures 4 and 5, using the two monitoring wells in close proximity to SRBT as an example. The relatively good match between the modeling results and measurements provides validation to CNSC staff’s 2010 prediction on the behaviors of tritium in the groundwater system. It also demonstrates that releases of tritium resulting from SRB’s operation are under control and the tritium movement in groundwater around the SRB facility is well understood”

Here is what independent scientist, Dr. Ole Hendrickson found when he looked at the same data:

“In fact, Figure 5 indicates a poor match between the modeling results and actual tritium measurements in monitoring MW07-13.  None of the results for the 15 most recent samples taken from this monitoring well are within the range predicted by CNSC staff’s modeling assessment.  All had consistently higher tritium contamination than predicted by CNSC staff.”

Dr. Hendrickson goes on to say:

“Even more troubling is that the Environmental Assessment Information Report omits data for the other two monitoring wells modeled in the Update on Tritium Contamination in Groundwater at SRBT:  MW07-18 and MW07-29.  In these two wells, the agreement between the CNSC staff model and actual measurements is very poor.  Table 1 shows that during 2014, MW07-18 and MW07-29 had average tritium contamination levels 3.3 and 10.9 times higher than CNSC staff predictions, respectively.

“One must conclude that the statement on page 11 of 18 of the Environmental Assessment Information Report that “SRB’s operation has not adversely affected the groundwater quality” is false.  The mismatch between predicted and measured groundwater tritium contamination indicates that releases of tritium resulting from SRBT’s operations are not under control and the tritium movement in groundwater around the SRBT facility is not well understood.”

You can read Dr. Hendrickson’s full report, prepared for The First Six Years, here on the TAP website:  Tritium Behaviour in the Vicinity of SRB Technologies

Documents prepared for the CNSC’s public hearing on SRB Technologies reveal shocking levels of incompetence or corruption in CNSC staff.

Dr. Ole Hendrickson in his report prepared for The First Six Years, noted the following statement by CNSC staff:

“radioactivity measured in water, air, soil, vegetation, milk, wine, fruits and vegetables samples…are within natural background levels”

Background tritium levels are considered to be 2 Bq/l according to CNSC. Several vegetable samples from Bowdens Gardens in Pembroke measured in the hundreds of becquerels per litre of tritium. CNSC staff’s statement (in quotation marks above)  therefore reveals a shocking misunderstanding of what background tritium levels are, or a deliberate attempt to mislead readers.

Additional problems noted by Dr. Hendrickson  include: lack of information on methodology employed for sample analysis, use of non-standard units (Bq/kg fresh weight), lack of clarity as to whether tritium concentrations in vegetation include organically-bound tritium, and the failure to provide a source for “Guidance/Reference levels”

TAP suggests that staff responsible for stating that tritium levels in water, air, soil, vegetation, milk, wine, fruite and vegetables are within natural background levels, should be fired, or at the very least sent back to school to learn basic science.

The Canadian Nuclear Safety Commission allows members of the public to make oral presentations at licensing hearings, but only allows 10 minutes per person or group. There are no restrictions on the licensee or the CNSC staff who are permitted to drone on ad libitum.

It is patently ridiculous that intervenors who spend  hundreds of hours researching and preparing submissions, essentially doing the CNSC’s work for it, are restricted to a 10-minute oral presentation. Even those intervenors who receive funding from the CNSC to partially compensate them for time and expenses involved in presenting, are restricted to 10 minutes.

In today’s hearing, for example, the First Six Years received intervenor funding and hired Dr. Ian Fairlie and Dr. Ole Hendrickson to prepare reports on The Hazards of Tritium Releases and SRB Pembroke and Tritium Behaviour in the Environment near Pembroke. You can read these reports in full here on the TAP website (links below). The First Six Years will be restricted to a 10 minute time slot for the oral presentation, time to cover only a small fraction of the substantive new information from the two reports.

The Hazards of Tritium Releases at SRB Pembroke 

Tritium Behaviour in the Vicinity of SRB Technologies

The Canadian Nuclear Safety Commission public hearing re the application by SRB Technologies for a 10-year license is taking place today in Pembroke at the Best Western Pembroke Inn and Conference Centre beginning at 9:00 am. Members of the public are welcome to attend. The hearing will also be webcast on nuclearsafety.gc.ca

Intervenors will include the following:

Dr. Ian Fairlie and Kelly O’Grady on behalf of The First Six Years

Dr. Gordon Edwards on behalf of the Canadian Coalition for Nuclear Responsibility

Dr. Ole Hendrickson on behalf of Concerned Citizens of Renfrew County

Lake Ontario Waterkeeper and Ottawa Riverkeeper

Prevent Cancer Now

Science for Peace

and several individuals.

Canadian Coalition for Nuclear Responsibility (CCNR) makes a strong case against a 10-year license for SRB Technologies in its recent  submission to the Canadian Nuclear Safety Commission.

CCNR points out that Pembroke has been subjected to widespread tritium contamination due to incompetence of the regulator, CNSC, formerly the Atomic Energy Control Board. AECB essentially granted SRBT a license to market nuclear waste (tritium) that had been carefully segregated from heavy water by Ontario Power Generation and stored in stainless steel containers in a concrete vault at the Darlington Tritium Removal Facility. AECB allowed SRB to set up in a populated area in Pembroke, close to residences and businesses, with no exclusion zone. AECB did not properly oversee SRBT’s activities or require environmental monitoring for the first decade of its operation.

The Coalition urges current commission members to not compound the mistakes of their predecessors by allowing tritium emissions to continue in Pembroke, given that even if emissions are better controlled than before, tritium levels will continue to increase in the environment, due to the long half-life of tritium. CCNR argues that the SRBT facility should be either shut down altogether unless they can reduce radioactive emissions to zero, or they should be forced to relocate to an industrial or research site with an enforced exclusion zone such as Chalk River Labs.

The Coalition also raises serious concerns about the potential for tritium in the tubes that are filled at SRBT in Pembroke to end up in nuclear weapons.

Ontario Power Generation (OPG) runs the Darlington Tritium Removal Facility to reduce the tritium content of heavy water used to moderate CANDU reactors, protecting workers and the environment. This facility produces and stores 1-2 kilograms of pure tritium gas each year. OPG ships around 100 grams of tritium annually to the Chalk River Tritium Laboratory (part of the Canadian Nuclear Laboratories, formerly AECL) whose primary function is to dispense tritium for OPG’s commercial tritium customers. SRB is the main customer, processing 85 grams of tritium in 2013. While 85 grams of tritium sounds like a tiny amount, David Albright and Theodore B. Taylor (“Making Warheads: A Little Tritium Goes a Long Way”, Bulletin of the Atomic Scientists, Jan. 1988) explain that only 2-3 grams of tritium are needed to boost the yield of a nuclear bomb several-fold. SRB processes enough tritium each year to supply 20-30 nuclear weapons.

CNSC is proposing to remove licence conditions for safeguards and non-proliferation from SRB’s licence. No reason is given for the proposal.

TAP finds this proposal bizarre and maintains that Canada must uphold its obligation under the Treaty on the Non-Proliferation of Nuclear Weapons “to accept safeguards… with a view to preventing diversion of nuclear energy from peaceful uses to nuclear weapons or other nuclear explosive devices.”

A research study led by the CNSC’s own scientists, published in a peer-reviewed scientific journal in 2015, found unexpectedly high levels of organically-bound tritium (OBT) in soils and vegetation near SRB. A cucumber sampled 4.8 km from SRB contained 117 Bq/L OBT, 15.4 times the tritium in the cucumber’s water. Soil sampled 400 meters from SRB contained 1010 Bq/L OBT, 9.9 times the tritium in soil water. OBT in soil or living organisms, including humans, can have very long residence times and is therefore even more hazardous than tritium in water. OBT is generally not included in routine vegetation sampling. CNSC documents for the May 13^th hearing make no mention of these findings of high OBT near SRB, raising concerns about CNSC’s integrity and impartiality.

SRBT discharges tritium-contaminated water into Pembroke’s sanitary sewer system.  Annual discharges during the 2010-2014 period ranged from 7-13 GigaBecquerels (a GigaBecquerel (GBq) is the amount of a radioactive substance that produces one billion radioactive disintegrations every second).  CNSC sets a 200 GBq limit for SRBT’s liquid discharges.

The City of Pembroke’s sewage treatment plant receives SRBT’s liquid discharges of tritium.  Some of the tritium becomes incorporated in sewage sludge, while the remainder is discharged to the Ottawa River.  A recently published study, Measurements and Dose Consequences of Tritium in Municipal Sewage Sludge, found that Pembroke had the highest levels of tritium contamination in sewage sludge of any city studied, at 34 Bq/kg of HTO, and 400 Bq/kg of OBT, or 1800 Bq/kg dry weight (CNSC 2015c).  According to this study, “A 38 percent increase was observed in the measured OBT concentration of the 2014 sample compared to the one obtained in 2013.”

The study does not examine the potential for tritium contamination of soil and crop plants if Pembroke sewage sludge were to be spread as biosolids on agricultural land.  It says that sewage sludge from Pembroke’s sewage treatment plant “is currently disposed of at the Ottawa Valley Waste Recovery Centre” (CNSC 2015c).

A two-day hearing is scheduled for May 13 and 14th in Pembroke, Ontario where the Commission will hear arguments for and against a 10 year license for SRBT.
The public is invited to submit written comments and/or make an oral presentation at the hearing. Deadline for submissions is April 13, 2015. More info here.

TAP says a 10-year license is not appropriate given the history of license violations and environmental tritium contamination at this facility.