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.”

These findings are a warning sign that tritium contamination is widespread around SSI. However, CNSC staff do not see it that way. They state, for the record, that something unusual about apples causes them to concentrate tritium more than other types of vegetation. To quote from the transcript:

“We did observe as well that apples have this unique characteristic of having fairly high tritium concentrations even far away from some facilities and this is a subject of — will be the subject of some future research efforts to look at how apples are behaving this way. “

The CNSC is mandated to protect Canadians from radioactive pollution. Yet, CNSC staff repeatedly fall short in this regard. They seem unable to understand that tritium gas, which SSI releases from its stack, is readily oxidized to radioactive water, spreads throughout the environment and is incorporated into all organisms living nearby – including humans. Please see the tritium primer on this website for more on this.

“CNSC has currently set the derived release limit for HT from SSI at 3.40E+19 Bq/year (3.4 x 1010 GBq/a). This is over 200 times higher than the total global natural tritium production rate, and more than ten times the total world steady state natural inventory of tritium. (emphasis added)

Each year during the past five years, in theory, SSI could have emitted more than ten times the world’s current natural tritium inventory. Had they done so, tritium levels in rainfall, and in every water body in the world, would have risen several hundred-fold, reaching levels exceeding those measured at the peak of nuclear weapons testing in 1963.

This would trigger a global health crisis. There would be a tremendous outcry from scientists, health professionals and civil society around the world.

This scenario, of course, is impossible. All the reactors in Canada could not produce enough tritium for SSI to do this. No responsible regulatory agency would accept such absurd tritium release limits.

But when it comes to tritium – indeed, when it comes to all environmental releases of radionuclides – the CNSC is not a responsible regulatory agency.”

The statement that the CNSC is not a responsible regulatory agency was confirmed when the Commission awarded SSI its current 3-year license in July 2009. The CNSC retained SSI’s “Derived Release Limits” in Appendix E of the license.

Why did CNSC act so irresponsibly on tritium limits when the problem had been clearly raised during the licensing hearing?

Incorporating absurd release limits in licenses is CNSC’s way of covering up radiation releases. This was clearly illustrated when SSI had a large accidental release of tritium gas in February 2010. Section 3.3 of CMD 11-M8, prepared by CNSC staff for SSI’s January 2011 mid-term hearing, says the following:

“On February 1, 2010, SSI released 147.25 Terabecquerels (TBq) of tritium gas into the environment due to an accidental release from the Tritium Fill Machine, which exceeded SSI’s weekly action level of 17 TBq, but is far below the licence release limits of 34 million TBq/year.”

In making this statement, CNSC staff misled Commissioners and greatly understated the severity of SSI’s February 2010 accident. They failed to tell Commissioners that Appendix E of SSI’s license, in addition to the “derived release limits”, also contains “release limits”. Under condition 4.1 of its license, SSI “shall not exceed” these limits. During the February 2010 accident (which apparently only lasted about five minutes – CNSC has refused to release details) SSI released 30% of its legal yearly limit for tritium gas.

Derived release limits are calculated by licensees themselves – not by the CNSC. SSI’s derived released limits are absurd, and have no legal effect. Why have two limits for radioactive emissions from a Canadian nuclear facility?

The answer is simple. The far higher derived release limits serve the CNSC and licensees as a useful communications device: a way to assure the public that radiation releases – whether “routine” or accidental” – are of no concern. For years, Canada’s nuclear regulatory agency has used derived release limits in this fashion. Canadian radiation release limits (derived or otherwise) generally greatly exceed those for nuclear facilities of equivalent size in other countries.

Does the CNSC intend to continue its practice of incorporating dual release limits in its licenses – one limit for communications purposes, and another limit for legal purposes?

Shamefully, the answer appears to be  “Yes”. A new draft operating license for SSI, prepared by CNSC staff for the Commission’s May 2, 2012 public hearing on SSI, still includes “derived release limits”, of 34 million trillion Becquerels of tritium per year, unchanged from past licenses.

In the case of SSI,  there is no signage or any indication  of the tritium hazard. Unbelievably there is a picnic table right beside the stack. Read more in the SAGE intervention for the upcoming hearing at the CNSC on May 2, 2012.

“My initial perusal indicates that this another highly slanted, misleading, CNSC defence of the practice of releasing very large amounts of tritium near Canadian nuclear power facilities. It is perhaps revealing that the report (Figs 5 and 6) shows high tritium levels very near the SRB facility at Pembroke, but remains silent about the high tritium intakes by people near nuclear power facilities.

The report takes a hesitant one step forward in actually mentioning the ACES and ODWAC reports (for the first time by CNSC). But two steps backward in refraining from discussing the concerns about tritium which led to the reports.

The report has many defects and omissions but the main deficiency is that it ignores the mounting scientific evidence from radiation biology that tritium is a serious health hazard.”

Documents filed for the hearing show tritium contamination at the base of SSI’s stacks has exceeded 1,000,000 Becquerels per litre. Local apples and groundwater wells are contaminated at many times higher than background levels. 

 SSI’s current license permits it to release 34,000 quadrillion becquerels of tritium. This is an unbelievably large quantity. So large it’s hard to put into words. But suffice it to say that SSI’s current license permits it to release more than the current total global inventory of tritium.

Of course SSI’s actual tritium releases are only a small fraction of their allowable limit*. But a small fraction of an enormous number can still be a large amount.

This is all eerily familiar. Citizens of Pembroke have been through this with our own tritium sign factory, SRB Technologies Incorporated. Soil and groundwater in the vicinity of SRB remain highly contaminated with tritium and nearby residents have stopped growing vegetables for home consumption. Some still grow a few veggies to use for monitoring tritium contamination every year.

Members of the Tritium Awareness Project will be intervening in the licensing hearing for SSI on June 10th. Members of the public who are interested in intervening must contact the CNSC  by May 13th. Details for intervenors are available on the CNSC website at www.cnsc-ccsn.gc.ca/eng/

Members of the public can also sign and/or collect signatures on the TAP petition to phase out the use of tritium lights. The petition is located here.

* due to the CNSC’s strange practice of setting allowable limits more than a thousand times higher than actual releases, an approach that is contrary to guidance from the International Atomic Energy Agency.

Various American authorities have recently posted detailed information on the internet about responsible management of  tritium EXIT signs. Authorities in the United States appear to be way ahead of their Canadian counterparts in addressing the serious problems created by use and disposal of  these signs, many of which are manufactured in Canada.

In the U.S.,  the Department of Defense, National Institutes of Health and Environmental Protection Agency all have prohibited use of tritium signs. Here are two informative web resources created recently by American authorities.

1) Responsible Management of tritium EXIT signs - excellent on-line training module from the Environmental Protection Agency that includes information on health risks, a key to identify tritium signs, recommended alternatives, and safe procedures for disposal.

2) Bureau of Radiation Protection, State of Pennsylvania - detailed webpage with much information about the problems with tritium exit signs.

TAP asks “Where is Canada’s information on responsibly dealing with tritium exit signs”?  

Besides being hazardous during manufacture and disposal, tritium lights and products containing them are hazardous during use. The tritium contained in a single exit sign, if fully oxidized and inhaled would constitute a lethal dose of radiation. Incidents have occurred in the United States where lights have been accidentally or intentionally broken, thus requiring expensive emergency measures including evacuations and decontamination operations.

This and other problems are described in the TAP fact sheet “Problems with tritium exit signs” available in PDF format for download in the documents section of this website.

Disposal of waste exit signs can seriously pollute groundwater. Tritium lights become much more hazardous to the environment as they age; the glass tubes act as sponges for tritium, converting it into its more hazardous and soluble oxidized form. Information linking high levels of tritium oxide in landfill leachate to discarded exit signs, has recently come to light in Scotland, South Africa, Italy and several states in the U.S. Regulators are grappling with the issue of how to ensure that used tritium exit signs go to monitored, radioactive waste storage facilities (1,2). Although no Canadian data are available, the situation may be worse here because regulations allow for disposal of used exit signs in ordinary landfills.

References:

1) Study of tritium in leachate from Scottish landfill sites
2)  State of Pennsylvania Department of Environmental Protection

SRB  was licensed by the Atomic Energy Control Board (now the Canadian Nuclear Safety Commission) in 1990  to market a radioactive waste byproduct of CANDU reactors called tritium — a radioactive form of hydrogen. SRB makes self-illuminating signs — they glow in the dark because they are filled with large quantities of radioactive tritium gas.  

Over the years. SRB has contaminated the environment in Pembroke with high levels of tritium. In some years, more tritium was given off into the environment by the SRB plant than by all of Canada’s nuclear power reactors combined.  Meanwhile, SRB is exporting tritium contamination problems around the world because there is no effective control over the ultimate disposal of these radioactive signs. 

This story is replete with patent examples of regulatory incompetence, murky questions about nuclear weapons and international security risks (because tritium is also used as a nuclear explosive material) and salt-of-the-earth folks being treated with disregard and exposed to high levels of radioactive tritium for  almost 20 years with no end in sight.  Please see also the “personal stories” category for more about this.

TAP feels that the marketing of radioactive wastes like tritium should be banned in Canada, and the SRB plant should be permanently shut down.