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.

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).

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.

A PDF version of the three-page CCNR intervention is available here .

“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.

This important public event organized by Safe And Green Energy (SAGE) Peterborough will be held Wednesday, April 11th, 7:00 pm at the George Street United Church located at the corner of George Street and McDonnel Street. The event titled “Tritium and the Quality of Life In Peterborough” is free and all are welcome.