Open letter to Dr. Michael Binder, president of the Canadian Nuclear Safety Commission

The Pembroke Observer: Kelly O'Grady, Pembroke, ON - May 29, 2010

CNSC staff recently produced a series of research studies on tritium called the Tritium Studies Project. Six of the reports are completed and available on the CNSC website (CNSC Open House: Tritium Studies Project April 28, 2010).

I have a special interest in these reports, particularly as tritium levels in my community of Pembroke began increasing in 1990 following the arrival of a Class 1b nuclear facility to the outskirts of town. This facility manufactures and recycles tritium- filled exit signs and gun-sights. From these reports I see that Pembroke now has the "dubious" distinction of being the "Tritium Capital of Canada."

Tritium, an isotope of hydrogen, is rare, making up less than one quadrillion per cent of all naturally occurring hydrogen; but it's certainly not rare in Pembroke. We are home to some of the most abundant tritium concentrations in Canada -in groundwater, soil, garden produce and air (Tritium Releases and Dose Consequences CNSC, 2009 and Evaluation of Facilities Handling Tritium, CNSC 2010). So much so, in fact, that our community was the subject of a special CNSC investigation (Tritium Activity in Garden Produce from Pembroke in 2007 and Dose to the Public, CNSC 2010).

There's even a communiqué on the CNSC website addressed specifically to us: "Pembroke: Topics of Interest" which states:

"The CNSC wishes to reassure members of the public that current tritium levels in drinking water do not pose a risk to their health. Tritium levels found in the municipal drinking water of communities near nuclear facilities are well below national and international standards, and below the 20 Bq/L limit proposed by the Ontario Drinking Water Advisory Council."

It is true that levels of tritium in municipal drinking water, in general, fall below the proposed Ontario drinking water standard, even in Pembroke. It is misleading, however, Dr. Binder, for the CNSC to reference municipal values when you and I are both aware of the presence of at least seven residential and business wells within Pembroke and the neighbouring community of Laurentian Valley with tritium concentrations at times exceeding 3,900 bequerels per litre.

These levels are well above the proposed Ontario drinking water standard and far above levels found in residential wells elsewhere in Canada -including those in the vicinity of other, larger nuclear facilities such as Pickering A, Bruce A, Gentilly, Point Lepreau, Darlington, and Chalk River (Tritium Releases and Dose Consequences, CNSC, 2009).

I am glad that the CNSC is providing the public an opportunity to respond, in writing, to these reports. I am disappointed however, that the CNSC has provided such a narrow window in which to do it. Submissions are due June 2 -hardly adequate time for a thorough review. The Pembroke study, one of the last to be released, was only made public April 27.

The Ontario Drinking Water Advisory Council recently recommended a substantial lowering of the provincial standard for tritium in drinking water (from 7,000 to 20 bequerels per litre) following extensive and extended public consultation.

Given the perceived importance of the CNSC reports in determining federal public health related policy, we hope the Commission will consider extending the deadline.