NUCLEAR GENOCIDE IN CANADA Part 6 Allowable Levels of Radiation  "What was not monitored was radiation from internal emitters which may have been breathed or swallowed or made their way into the body through any opening in the skin. These internal emitters of radiation, even at the single particle level, can and do cause the onset of disease." (John Clearwater, 2007 Report on Veterans Exposed to Atomic Testing in Canada) Allowable Doesn't Mean Safe There is no safe level of radiation. It's that simple. The presence of any radioactive material increases the risk of disease. If this material is lodged inside your body, the risk is much greater. Radioactive material inside your body is called 'internal emitters.' Internal emitters will be bombarding the cells next to it with radiation as they decay to another radioactive substance. Canada's regulatory regime for radiation emissions is based solely on doses received to the outside of the body. They do not take the far greater impact of the internal emitters into consideration. ALARA Principle (As Low As Reasonably Achievable) The Canadian Nuclear Safety Commission (CMSC) regulates allowable levels of radiation in Canada according to the ALARA Principle. The level of emergency preparedness involving the nuclear industry is also regulated according to the ALARA Principle. Although it refers to the ICRP Risk Model at times, the Canadian Government uses the ALARA Principle to set the allowable levels of radiation in Canada. Each nuclear facility in Canada determines its own allowable level of radiation based on what it feels is 'reasonably achievable.' As such, the allowable levels of radiation in Canada are set to ensure the profitability of the nuclear company instead of being set to protect the health of people living near the facilities. In 2005 the Municipality of Port Hope realized their fire department could not fight radiological fires and there was no warning system in place nor evacuation plan. The CNSC allowed Cameco to operate in the middle of town without required emergency protection. In response to Cameco's application to start processing enriched uranium in Port Hope, the town's Chief Administrative Officer (CAO) voiced his concerns: The Municipality should not rely solely on ALARA (As Low As Reasonably Achievable), the CNSC safety philosophy for off-site matters. Rather the Municipality should be proactive and require state of the art safety and response measures with respect to matters within its own jurisdiction. (Port Hope CAO, Mike Rostetter, Report to Council, 2005) The ALARA Principle makes a mockery out of Human Rights. Its use must be discontinued and replaced with the Precautionary Principle. Tritium Tritium is a radioactive form of hydrogen released to air and water by nuclear reactors. It has weak penetrating properties, but once inside the body, it is very dangerous. It can enter our bodies through ingestion, inhalation or directly through the skin. It is especially dangerous to pregnant women as it can cross the placenta to the baby. Many people living near nuclear reactors are concerned about the level of tritium in their drinking water. The health authorities in the Federal Government tell them not to worry as testing shows tritium to be below allowable limits. This is true most of the time; the emissions from these facilities are within allowable levels. However, when you compare the allowable level for tritium in drinking water in Canada to other countries, you do not feel safe. The allowable level of tritium in the European union is 100Bq/L while the United States sets a limit of 740Bq/L. The Canadian standard is 7000Bq/L. This is not a misprint Canada's limit must be set this high because the CANDU reactors release 30 times as much tritium to the environment as any other reactor in the world. This is because CANDU reactors use heavy water as both moderator and coolant. Refer to the 'Tritium Hazard Report By Dr. Ian Fairlie June 2007' for further information. In 1994, the Ontario government appointed Advisory Committee on Environmental Standards recommended that the maximum permissible concentration of tritium in drinking water be immediately reduced 70 fold to 100 Bq/L, and gradually dropped to 20 Bq/L over 5 years. Their recommendations were contained in a report called 'A Standard for Tritium: A Recommendation to the Minister of the Environment and Energy.' The recommendations were rejected. Radon Gas Radon gas is the second leading cause of lung cancer in Canada. It is responsible for about 2000 deaths per year. Health Canada is currently in the process of setting new radon gas exposure levels in Canada. Health Canada released the 'Report of the Radon Working Group on a New Radon Guideline for Canada.' The Working Group's first recommendation is:  Remedial measures should be undertaken in a dwelling whenever the average annual radon concentration exceeds 200 Bq/m³ in the normal occupancy area. This an attempt by Health Canada to raise the remediation criteria for a second time on properties that have been contaminated by the nuclear industry and the Canadian Government since elevated radon levels were discovered throughout Port Hope in 1975. In 1975, the allowable level for radon in a building in Ontario was 3pCi/L or 111Bq/m3 (metric equivalent) and it fell under the jurisdiction of the Ontario Government. Many properties in Port Hope at that time tested above 3pCi/L, including St. Mary's elementary School at 63 pCi/L. The Federal and Provincial Governments realized they had a large problem on their hands so they formed the Federal Provincial Task Force on Radioactivity (FPTFR): "to coordinate a national program of radioactive contamination assessment and remedial measures. The primary clean-up criteria for radon daughter products, is 20 Milli Working Levels (150 Bq/m3 radon equivalent)." (Atomic Energy Control Board, Info Bulletin 77-2) Instead of cleaning up the sites which had tested above the allowable level, they simply raised the allowable level 33%. As previously stated, Health Canada's proposed recommended remediation criteria is 200Bq/m3 or 5.4pCi/L. In other words, they have raised the remediation level for radon by 35% over the Federal Provincial Task Force on Radioactivity criteria or 80% since the contamination was first discovered in Port Hope in 1975. This will allow the government to avoid cleaning up potentially hundreds of buildings in Port Hope.  The 80% increase in the recommended remediation criteria is very troubling considering the U.S. Environmental Protection Agency, Health Canada, the U.S. National Academy of Sciences and the World Health Organization all say that there is no safe level of radon.  Most U.S. Environmental Protection Agency (EPA) lifetime safety standards for carcinogens are established based on a one in 100,000 risk of death. Most scientists agree that the risk of death for radon at 4 pCi/l, is approximately one in 100. At the 4 pCi/l EPA action guideline level, radon carries approximately 1000 times the risk of death as any other EPA carcinogen. The EPA and the Surgeons General's Office have urged widespread testing for radon. They estimate a family whose home has radon levels of 4 pCi/l is exposed to approximately 35 times as much radiation as the U.S. Nuclear Regulatory Commission allows if they were standing next to the fence of a radioactive waste site.  Neutron Radiation In December 2004, a group of people from different organizations measured a variety of sites around Port Hope with a scintillation counter (High tech Geiger counter). Several public sites we measured had radon levels more than 50 times higher than the allowable level. We went to Cameco's public parking lot to measure their trucks with full UF6 containers on board. We were shocked to find out the containers were giving off neutron radiation.  "Neutrons readily pass through most material, but interact enough to cause biological damage. Due to the high kinetic energy of neutrons, this radiation is considered to be the most severe and dangerous radiation available. Another, sometimes more severe, hazard of neutron radiation is neutron activation, the ability of neutron radiation to induce radioactivity in most substances it encounters, including the body tissues of the workers themselves." (Wikipedia)  There are no regulations in place in Canada limiting the levels of neutron radiation we are exposed to. Cameco and the Canadian Nuclear Safety Commission never told Port Hope residents or nuclear workers about the presence of neutron radiation.  Beryllium Zircatec Industries (fuel rod manufacturer) in Port Hope used beryllium in fuel rods as a neutron generator (called 'booster fuel') and as part of the welding process. There is no regulatory level for particulate beryllium in Canada, though some companies use the OSHA Standards from the United States. Beryllium disease erodes the lungs, making it hard for a victim to even walk across a room without severe pain and exhaustion, and usually results in a slow, painful death by suffocation. Beryllium disease is not limited to workers. 'Neighbourhood cases' of the disease were first documented in the 1940s when ten people who lived within a mile of the Brush Inc. plant were exposed to smokestack emissions of the toxic dust were diagnosed with beryllium disease. In 1948, the first of many cases among workers' wives was diagnosed. These women were exposed to the toxic metal dust while washing their husband's work clothes.  Increased Risk to Women and Children "Children are more sensitive to radiation than adults because they are growing more rapidly, there are more cells dividing and a greater opportunity for radiation to disrupt the process. Fetuses are also highly sensitive to radiation." (The U.S. Environmental Protection Agency) "The incubation time for cancer is five to 50 years following exposure to radiation. It is important to note that children, old people and immuno-compromised individuals are many times more sensitive to the malignant effects of radiation than other people." (Dr. Helen Caldicott, The Australian, April 15, 2005) "The same radiation in the first year of life for boys produces 3 to 4 times the cancer risk as exposure between the ages of 20-50. Female infants have almost double the risk as male infants." (BEIR 7 Report, Biological Effects of Ionizing Radiation) "Cancer mortality risks for women are 37% higher than for men. The risk for lung, breast, kidney and liver tumours are 50% greater in women." (BEIR 7 Report)  Children face a much larger risk from radon gas than adults because the heavy weight of radon gas forces it closer to the floor where the small children spend most of their time. Different Rules for the Nuclear Industry Port Hope residents discovered a broken pipe in 2008, dumping water contaminated with uranium and arsenic directly into Lake Ontario. The pipe is owned by Cameco Corporation and it drains treated water from the Welcome Radioactive Waste Management site. The residents had the effluent tested by Caduceon Environmental Laboratories in Peterborough Ontario. The report showed very high levels of arsenic and uranium found in the samples, but far more disturbing was the report showed three different allowable levels in place in Ontario for both arsenic and uranium; the Ontario Water Quality Objectives, the Canadian Drinking Water Guidelines and the Canadian Nuclear Safety Commission's allowable level for Cameco's license. For arsenic, the province of Ontario allows up to .005mg/L, the Canadian government allows up to .01mg/L and the CNSC allows up to .5mg/L. The CNSC allows Cameco to discharge 100 times more arsenic than the province of Ontario does. The level of arsenic found in the test sample was .02mg/L or four times as high as the provincial standard. For uranium, the province of Ontario allows .005mg/L, the Canadian government allows .02mg/L while the CNSC does not have an upper limit in place. Cameco's license allows them to dump as much uranium as they want into Lake Ontario from this pipe. The level of uranium found in the test sample was .246mg/L or 49 times higher than the level allowed by the Province of Ontario. There are allowable levels of radiation in place in Canada but they are not the same from one place to the next. For example, the allowable level of gamma radiation at Cameco's fence-line in Port Hope is six times higher than the allowable level at the fence-line of the nuclear reactors 12 miles away at Darlington. Cameco's facility is heavily contaminated from processing radioactive material for 75 years and the vast amount of radioactive material they handle prevents them from reducing gamma radiation levels to those found around the reactors. Modelling Over 90% of all substances released from Cameco to the air and water in Port Hope are modeled on a computer. There is hardly any real-time measurement of the contaminants coming from their uranium processing plant. Computer modeling can tell them what should be coming out of their stacks and other sources (points of impingement) but it does not tell them what is being released. There is no way for the modelling program to tell if an accidental release has occurred. There is no independent monitoring of Cameco or Zircatec's emissions to confirm the results of the modeling exercise. The Ontario Government was responsible for ensuring the accuracy of Cameco's reported emissions but they pulled out and cancelled all involvement several years ago.  The Cluff Lake Mine Environmental Assessment made extensive use of modeling. In his petition to the Auditor General on June 25, 2004, W.R. Adamson states: "In many instances, Cogema had not done recent field testing but took prior tests, some of them from the initial proposal for a licence, and simply projected them with computer modeling! Nature is a dynamic, changing, interrelated organism and does not go simply by computer numbering! Nature includes a lot of surprises!"  Environmental Assessments of sensitive and populated places are increasingly relying on modelling programs to prove the merits of a project. Modelling should be a secondary tool in assessments to confirm the findings of real-time measurement and observation. Internal vs. External Emitters The regulatory levels of radiation in Canada are concerned only with radiation exposures outside our bodies or external emitters.  Science has shown that radioactive material inside our bodies (internal emitters) is far more dangerous than on the outside. The reason for this is that when a radioactive particle lodges in a part of our body, it continually bombards the cells closest to it with radiation as it decays. This constant bombardment can cause disease, death or mutations in those cells. Change Allowable Levels In March of 2000, levels of tritium in groundwater at Bruce Power exceeded their operating limits because of undetermined leakage. This came at a bad time for Bruce Power as they were applying for a license renewal. The nuclear regulator solved the problem for them by making a 'special provision' to increase the operating limit by 500%. By December 2001, test results from groundwater monitoring wells had exceeded even the new levels enacted by the nuclear regulator. Last Word The regulatory levels in Canada concerning radiation exposure have been put in place to protect the nuclear industry and the Canadian Government. The CNSC's usage of the ALARA Principle to set allowable levels must be terminated as it provides no health protection. It is absurd that an industry as dangerous as nuclear is essentially allowed to regulate itself by determining what it can afford to spend to protect Canadian citizens. If they can't afford to protect us, get rid of the industry. End of Part 6