Jim Merritt
Chair, Ontario Drinking Water Advisory Council
40 St. Clair Avenue West, 3rd Floor
Toronto, Ontario, Canada
M4V 1M2

Dear Mr. Merritt,

The Tritium Awareness Project (TAP) is a voluntary collaborative initiative aimed at bringing attention to the hazards of tritium exposure in Canada. TAP is a new organization, formed in January 2009, and is supported by a growing number of individuals and NGO’s. The TAP advisory board members bring years of experience and professional expertise to this educational effort. We invite you to visit the TAP website at  www.tapcanada.org for more information about this initiative.

TAP supports the important work to date by the ODWAC to review the Ontario drinking water standard for tritium. This review has the potential to make a major contribution to reducing the tritium hazard in Ontario.

We are aware that the Canadian Nuclear Safety Commission (CNSC) is preparing a series of studies on tritium.  We understand that the ODWAC has been asked by the Canadian Nuclear Association to wait for the completion of these reports before finalizing its review and forwarding recommendations to the Minister of the Environment. We also understand that the ODWAC is currently reviewing draft versions of CNSC reports “Tritium Releases and Dose Consequences in Canada” and “Health Effects, Dosimetry and Radiological Protection of Tritium Beta Radiation” and that these drafts are not available to the public at present.

We would like to draw your attention to the fact that the CNSC does not have a health department, does not have any experts in radiation risk assessment on its staff, and tends to rely exclusively on nuclear industry funded scientists for advice. The first report in the CNSC tritium series “Standards and Guidelines for Tritium in Drinking Water” has been found seriously wanting by independent scientists, including TAP advisory board member, Dr. Rosalie Bertell, an internationally known expert in radiation risk assessment with 40 years of experience as an environmental epidemiologist.

Concluding her ODWAC submission on behalf of the International Institute of Concern for Public Health, Dr. Bertell had this to say about the CNSC’s first tritium report:
“The document is neither honest nor scientific from the point of view of public health. It is rather seriously and likely deliberately deceptive!”
In light of the above concerns, we believe it would be in the interests of ODWAC, the Ontario Ministry of Environment and the people of Ontario, to invite independent experts to review and provide critiques of the supplementary CNSC tritium reports before ODWAC prepares its final recommendations to the Minister.

We would like to therefore request:

1) that TAP be granted an opportunity to make a submission to the ODWAC on the Ontario Drinking Water Quality Standard for Tritium;

2) that an opportunity be given to TAP along with other interested groups and individuals to review, critique and provide supplementary recommendations to ODWAC in response to the CNSC’s series of tritium reports; and finally

3) that no undue weight be placed on the CNSC’s tritium reports.

Thank you very much for considering these requests.

We look forward to contributing further to this very important review of the Ontario Drinking Water Quality Standard for Tritium and sincerely hope that it will yield the best possible results for all concerned!

Yours sincerely,

Lynn Jones

on behalf of the
Tritium Awareness Project
Box 171
Pembroke, Ontario
K8A 6X3

cc. The Honourable John Gerretsen

Minister of the Environment

Radiation doses of 100 mSv [millisieverts] and more have shown increases in cancer incidence but there is no evidence of health effects at doses below about 100 mSv.
Frequently Asked Questions : Tritium

http://www.cnscccsn.gc.ca/eng/readingroom/factsheets/tritium_studies_faq.cfm

In his letter to CNSC President Michael Binder, Dr. Edwards says “The statement is scientifically incorrect and misleading. It suggests that a safe threshold of radiation exposure exists – a conclusion at odds with the widespread scientific consensus as found in many documents published by the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR), the US National Research Council (NRC), and the International Commission for Radiological Protection (ICRP).

Here is an excerpt from the TAP letter:

“On behalf of the Tritium Awareness Project, I urge the CNSC to discontinue the practice of allowing AECL to dilute and release tritium-contaminated water into the Ottawa River. This practice is unjustified, as it does no good and only harms the population that drinks the water.

Regulatory limits must not be regarded as a license to pollute.”

For the complete letter, continue reading:

Tritium Awareness Project (TAP)

Michael Binder, President,
Canadian Nuclear Safety Commission,
280 Slater Street, PO Box 1046 Station B,
Ottawa Ontario K1P 5S9

March 11 2009

Dear Mr. Binder:

Thank you for your letter of March 4, 2009, in response to mine of Feb. 16.

Your letter raises three main concerns:

The first has to do with the amount of radioactive tritium deliberately
released into the Ottawa River by AECL with the permission of the CNSC.

The second has to do with the concept of a “safe” dose of radiation in
general, and a “safe” concentration of tritium in drinking water in
particular.

The third has to do with the practice of deliberately diluting and releasing
tritium-contaminated water into the Ottawa River.

1. The amount of radioactive tritium deliberately released into the River.

You say that “there was no leak of radioactivity to the river” because “the
water released within the NRU building was collected and contained” and
then was sent to the Waste Treatment Centre, from which “subsequent
releases of tritium to the river have been controlled and monitored.”

However, since the Treatment Centre is unable to remove tritium from
contaminated water, all of the radioactive tritium that was sent to the
Treatment Centre did in fact end up in the Ottawa River. Instead of being
“leaked” into the river, it was – as you say – “released” into the river in a
manner which was “controlled and monitored”. By “controlled” I presume
you mean “diluted”.

Many people would like to find out just how much radioactive tritium
ended up in the Ottawa river – a question which I posed to you in my
February letter without yet receiving an answer. The answer is that as a
result of the December 5 heavy water leak at the NRU reactor more than 25
trillion becquerels of tritium ended up in the Ottawa River.

I believe the CNSC has a responsibility to communicate this kind of
information in a forthright manner to the citizenry and to their elected
representatives. This responsibility in enshrined in the Nuclear Safety and
Control Act, which obligates the Canadian Nuclear Safety Commission to
“disseminate objective scientific information” about the activities of the
Commission and its licensees.

2. The concept of a “safe” radiation dose and a “safe” concentration of
tritium in drinking water.

You state in your letter, “At no time was the public or the environment at
risk.” This is not objective scientific information; this is an opinion.

I believe the CNSC is obliged to provide the public with objective scientific
information about the nature of the health risks that accompany exposure
to ionizing radiation.

Much scientific evidence has existed for many decades on this subject. The
overwhelming consensus is that there is no such thing as a “safe dose” of
exposure to ionizing radiation – or, for that matter, to any other carcinogen.
The US National Academy of Sciences (NAS) examined claims from the
nuclear industry and its proponents that there might be a “safe threshold” of
radiation exposure, and rejected those claims as having no scientific validity.

In a 2007 press release announcing the publication of the NAS BEIR-VII
Report on the Biological Effects of Ionizing Radiation, we read:

WASHINGTON (June 2007) – A preponderance of scientific
evidence shows that even low doses of ionizing radiation, such
as gamma rays and X-rays, are likely to pose some risk of adverse
health effects, says a new report from the National Academies’
National Research Council.

The report’s focus is low-dose, low-LET – “linear energy
transfer” – ionizing radiation that is energetic enough to break
biomolecular bonds. In living organisms, such radiation can
cause DNA damage that eventually leads to cancers. However,
more research is needed to determine whether low doses of
radiation may also cause other health problems, such as heart
disease and stroke, which are now seen with high doses of low-
LET radiation.

The study committee defined low doses as those ranging from
nearly zero to about 100 millisievert (mSv) ….

“The scientific research base shows that there is no threshold of
exposure below which low levels of ionizing radiation can be
demonstrated to be harmless or beneficial,” said committee chair
Richard R. Monson, associate dean for professional education
and professor of epidemiology, Harvard School of Public
Health, Boston.

The International Commission on Radiological Protection (ICRP) makes
the same point in a publication that is featured on their current web site:

Both low and high doses [of ionizing radiation] may cause
stochastic, i.e. randomly occurring, effects (cancer and
hereditary disorders)…. The probabilistic nature of the
stochastic effects makes it impossible to make a clear
distinction between ‘safe’ and ‘dangerous’, a fact that causes
problems in explaining the control of radiation risks. The
major policy implication of a non-threshold relationship for
stochastic effects is that some finite risk must be accepted at
any level of protection. Zero risk is not an option.

INTERNATIONAL COMMISSION ON RADIOLOGICAL PROTECTION:
HISTORY, POLICIES, PROCEDURES http://www.icrp.org/docs/Histpol.pdf

The CNSC, in keeping with its mandate, should make these easy-to-
understand explanations of radiation risks available on its web site for the
education of Canadian citizens and policy makers, and desist from
misleading Canadians to the contrary.

In particular, the CNSC should remove from its web site this statement:

Radiation doses of 100 mSv [millisieverts] and more have shown
increases in cancer incidence but there is no evidence of health
effects at doses below about 100 mSv.
Frequently Asked Questions : Tritium

http://www.cnsc-ccsn.gc.ca/eng/readingroom/factsheets/tritium_studies_faq.cfm

The statement is scientifically incorrect and misleading. It suggests that a
safe threshold of radiation exposure exists – a conclusion at odds with the
widespread scientific consensus as found in many documents published
by the United Nations Scientific Committee on the Effects of Atomic
Radiation (UNSCEAR), the US National Research Council (NRC), and the
International Commission for Radiological Protection (ICRP).

3. The practice of diluting and releasing tritium-contaminated water
into the Ottawa River.

The linear non-threshold relationship espoused by leading authorities in
the field of radiation protection implies that the harmful stochastic effects
from even a low dose of ionizing radiation is proportional to the number
of people exposed. Even diluted tritium levels will result in additional risk
to these exposed populations, including MPs in the House of Commons.

The Ottawa River serves as a source of drinking water for more than a
million people. Water treatment facilities cannot remove the radioactive
tritium from drinking water. In light of these indisputable facts, AECL’s
practice of diluting and releasing tritium-contaminated water into the
Ottawa River must be seriously reassessed.

Quoting again from the document ICRP: History, Policies, Procedures:

The major policy implication of a non-threshold relationship for
stochastic effects is that some finite risk must be accepted at any
level of protection. Zero risk is not an option.

This leads to the basic system of protection which has three
components -

(1) the justification of a practice, which implies doing more good
than harm,

(2) the optimisation of protection, which implies maximising the
margin of good over harm, and

(3) the use of dose limits, which implies an adequate standard of
protection even for the most highly exposed individuals.

Over the years there has been confusion over the meaning of the
Commission’s dose limits. The Commission now regards these as
being close to the point where the doses from the sources to
which the dose limits apply result in a level of risk that, if
continued, could legitimately be described as unacceptable for
those sources in normal circumstances. Compliance with dose
limits is then a necessary, but not a sufficient, condition for
complying with the Commission’s recommendations.

On behalf of the Tritium Awareness Project, I urge the CNSC to discontinue
the practice of allowing AECL to dilute and release tritium-contaminated
water into the Ottawa River. This practice is unjustified, as it does no good
and only harms the population that drinks the water.

Regulatory limits must not be regarded as a license to pollute.

Please share this letter with your fellow Commissioners. I thank you in
advance for your attention to these matters.

Yours very truly,

Gordon Edwards, Ph.D.,
53 Dufferin Road, Hampstead QC, H3X 2X8
e-mail: ccnr@web.ca phone: (514) 489 5118
For the Tritium Awareness Project

cc. Minister of Natural Resources
Mayors of Ottawa, Pembroke, and Petawawa

Putting radioactive materials in people’s drinking water is not wise, no matter what current regulations say.

Medical doctors do not recommend that people “smoke in moderation”. They tell them to stop smoking altogether.

Restaurants are not asked to oversee a permissible level of second-hand smoke. They are ordered by law to disallow it altogether.

The reason is that cigarette smoke is cancer causing. There is no scientifically accepted safe level of exposure to any known carcinogen. That goes for radioactive materials as well as for non-radioactive ones.

For the Canadian Nuclear Safety Commission to say that deliberately dumping eighteen trillion becquerels of tritium into the Ottawa River is “of no concern” and “perfectly safe” is not only scientifically wrong, but it is contrary to that organization’s legal mandate to protect the public health and to disseminate objective scientific information.

It is deeply distressing to see how the polluter (AECL) and the regulator (CNSC) join forces to obscure the facts and to provide unscientific reassurances of safety to the public and to their elected representatives.

Gordon Edwards, Ph.D., President,
Canadian Coalition for Nuclear Responsibility

The Honourable Lisa Raitt
Minister of Natural Resources Canada

February 27, 2009

Dear Minister Raitt:

Due to an oversight this correspondence was not sent to you on February 16 when it was sent to Mr. Pilkington.

I am very disappointed that you, as the responsible Minister, have not been given full and accurate information on this important subject.  Not only were the details of the spill and subsequent controlled releases not communicated to you in a clear and unequivocal manner, but the possible health impacts have also been misrepresented to you.

It is a well known fact in the medical community that there is no “safe threshold level” for any known carcinogen, and that includes radioactive materials such as tritium.  The number of cancers that may result from any given exposure is proportional to the population of people receiving that dose.

Thus a tritium contamination level that is considered small by some types of reckoning becomes more significant when millions of people are exposed to that small dose.  To say there is “no health concern” is simply to deny the fact that there is always a legitimate concern when carcinogens are ingested by large populations of people.

I would be happy to provide you with additional references on this point if it would be of use to you.  May I just refer you now to the US National Academy of Sciences BEIR VII Report (BEIR = Biological Effects of Ionizing Radiation) which investigated and found no reliable scientific evidence to conclude that any level of exposure is “safe”, and a great deal of evidence to conclude the opposite: that any exposure level, no matter how small, if administered to a large enough population, will cause an increase in the incidence of cancer.

With my best wishes,

Gordon Edwards, Ph.D., President,
Canadian Coalition for Nuclear Responsibility.

Bill Pilkington, Senior Vice-President,
Chief Nuclear Officer for AECL’s Research and Technology Operations,
Atomic Energy of Canada Limited,
Chalk River Ontario K0J 1J0

February 16 2009

Dear Mr. Pilkington:

The public and the House of Commons have been given assurances by the Minister of Natural Resources that no radioactivity has leaked into the Ottawa River as a result of the heavy water spill at Chalk River’s NRU reactor on December 5 2008.

Our information suggests that trillions of becquerels of tritium had already been released into the atmosphere when these assurances were given, some of which would surely find their way into the Ottawa River, and tens of trillions of becquerels of tritium in liquid form are being released (or have already been released) into the Ottawa River by Chalk River authorities, with the permission of the Canadian Nuclear Safety Commission, as a direct result of the heavy water spill at the NRU reactor on December 5, 2008.

We believe that the public has the right to know the amount of tritium that has been released into the environment as a result of this accidental spill and subsequent decisions made by AECL and CNSC authorities. Please provide the correct figures for the total amount of tritium (in becquerels) released into the atmosphere and the total amount of tritium (in becquerels) released or planned to be released into the Ottawa River as a result of the December 5 incident.

Thank you for your attention to this matter.

Yours very truly,

Gordon Edwards, Ph.D.,
53 Dufferin Road, Hampstead QC, H3X 2X8
e-mail: ccnr@web.ca phone: (514) 489 5118
For the Tritium Awareness Project

cc. Minister of Natural Resources
Mayors of Ottawa, Pembroke, and Petawawa

Michael Binder, President,
Canadian Nuclear Safety Commission,
280 Slater Street, PO Box 1046 Station B,
Ottawa Ontario K1P 5S9

February 16 2009

Dear Mr. Binder:

The public and the House of Commons have been given assurances by the Minister of Natural Resources that no radioactivity has leaked into the Ottawa River as a result of the heavy water spill at Chalk River’s NRU reactor on December 5 2008.

Our information suggests that trillions of becquerels of tritium had already been released into the atmosphere when these assurances were given, some of which would surely find its way into the Ottawa River, and tens of trillions of becquerels of tritium in liquid form are being released (or have already been released) into the Ottawa River by Chalk River authorities, with the permission of the Canadian Nuclear Safety Commission, as a direct result of the heavy water spill at the NRU reactor on December 5, 2008.

We believe that the public has the right to know the amount of tritium that has been released into the environment as a result of this accidental spill and subsequent management decisions by AECL and CNSC authorities.

Please provide the correct figures for the total amount of tritium (in becquerels) released into the atmosphere and the total amount of tritium (in becquerels) released or planned to be released into the Ottawa River as a result of the December 5 incident.

We also believe that CNSC Commissioners are being misled by CNSC staff when they are told (in CMD 09-M7) that ” monitoring of radioactivity in the Ottawa River has indicated comparable average concentrations up and down stream of the CRL site in the Ottawa River.”

Our information is that concentrations of tritium in the Ottawa River just downstream from CRL (at the site boundary) are at least 30 times greater than they are at the upstream CRL site boundary, and that tritium levels further downstream (from Harrington Bay to Pembroke and beyond) are at least twice the levels of tritium upstream from CRL. Why is CNSC staff not communicating accurate information to the Commissioners?

Thank you for your attention to these matters.

Yours very truly,

Gordon Edwards, Ph.D.,

53 Dufferin Road, Hampstead QC, H3X 2X8
e-mail: ccnr@web.ca phone: (514) 489 5118
For the Tritium Awareness Project

cc. Minister of Natural Resources
Mayors of Ottawa, Pembroke, and Petawawa