Letter to the editor of the Pontiac Journal, May 6. 2018

Dear Editor

Michael Rinker of the Canadian Nuclear Safety Commission (CNSC) writes in your April 25 edition, “As Canada’s independent nuclear regulator, I assure readers that radiation limits are set by the CNSC to protect human health”.  He goes on to say that derived release limits “restrict” the amount of radioactive material released to the environment by a licensed facility.

Your readers should know that the US National Research Council has reviewed all of the scientific evidence several times since 1980 and has repeatedly concluded that there is no safe level of exposure to manmade radioactive emissions from nuclear facilities. (1) Each and every release, no matter how small, increases risks of cancer, genetic mutations, birth defects and other adverse effects on humans and other living organisms exposed to them.

So does Mr. Rinker’s statement hold up? No unfortunately it does not. In fact, rather than protecting human health, “release limits” are doing quite the opposite. They are allowing risks to human health, in exchange for benefits to society-at-large produced by the nuclear industry. Since the benefits are not always clear, and since no one asked people downwind and downstream if they agree to being exposed for the sake of society-at-large, this is a problem.

Here are some other problems with CNSC “release limits” for radioactive material that might interest your readers:

– The release limits are actually created by the licensees not the CNSC. And, the CNSC allows licensees to create a separate release limit for each and every one of hundreds of radionuclides it releases, each one based on releasing up to the public dose limit for that radionuclide.

– CNSC allows each facility to create release limits that theoretically allow it to release each radionuclide up to the public dose limit, even though members of the public can be exposed to releases from more than one facility. For example, people in the Ottawa Valley are subject to radioactive releases from the defunct NPD reactor at Rolphton, from the Chalk River Laboratories, and from SRB Technologies in Pembroke which releases tritium to the air, groundwater, and the sewer system. Each one of these facilities sets its own release limits that allow it to release up to the public dose limit for each and every radionuclide it releases.

– Release limits are set quite high such that actual releases look very small in comparison. The CNSC is fond of telling us for example, that such and such release was only one ten thousandth of the release limit.

The CNSC acknowledged problems with its approach to setting derived release limits in a discussion document in 2012, called “Process for establishing release limits and action levels at nuclear facilities.  Discussion Paper DIS-12-02.   February 2012.

The problems remain. The fact that CNSC allows these problems to persist, appears to be further evidence that the CNSC is a “captured agency” that prioritizes promotion of the nuclear industry over protection of health and the environment.

Yours sincerely,

Lynn Jones, M.H.Sc.

L’isle-aux-Allumettes, Quebec

(1) National Research Council. 2006. Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII Phase 2. Washington, DC : The National Academies Press.