TAP Canada

March 29, 2009

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