“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

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.

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

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.

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.

(From the Website of Shield Source Incorporated on April 8, 2012)

“PUBLIC NOTICE – APRIL 2012

On March 28, 2012, we suspended operations to investigate potential errors in calculated HT emission data.  HT is tritium gas that is emitted in small quantities from our exhaust stack during our production process.  The CNSC was notified of this decision on the same day.

After consultation with independent consultants and the CNSC, we have decided to hire a third party consultant to install a parallel monitoring system to verify emission data during a limited production three day test scheduled to commence on April 3rd. Based on the values under consideration, this is not considered a threat to the public.  Verified independent environmental sampling of air, water, and vegetation remains at historically safe levels.  Additional information will be posted on this website as soon as it’s available.”

Note that SSI refers to “small quantities of tritium gas” being emitted from its exhaust stack. In fact, the tritium light factories, SSI in Peterborough, Ontario and SRB Technologies in Pembroke, Ontario are the two largest point sources for tritium gas emissions in the world, as far as we are aware.