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Tritium Drinking Water Standard

by Siegfried (Ziggy) Kleinau

My name is Siegfried Kleinau, better known as Ziggy, I am here representing over 1,000 members of Citizens For Renewable Energy (CFRE), a non-profit organization, incorporated in Ontario in 1996.

I am not a scientist, but I have been involved in numerous interventions before the AECB and its successor the CNSC. I attended a symposium on Low-Level radiation at McMaster U. 2 years ago and the Workshop on the Assessment and Control of Tritium’s Health Risk in Ottawa , sponsored by the CNSC, this January.

Clusters of our members live near Ontario’s nuclear plants, many near the Bruce nuclear station, the largest nuclear facility in North America, with 6 reactors operating, and two being refurbished. Tritium is being emitted during normal operation, and spills are not infrequent. Tritium cannot be filtered out by water treatment plants as stated by MOE.

Tritium is classified as a carcinogen by the USEPA.

So, to address the questions posed by the Council:
The answer to the first one is a CATEGORICAL NO.

The second question can be answered by addressing the long-term controversy on setting acceptable dose limits for exposure to this highly radioactive nuclide which is chemically identical to hydrogen and assimilates as tritiated water(HTO) into all places where hydrogen is to be found. That applies to the human body where it comes into intimate contact with almost every molecule, including the DNA, RNA and messenger RNA. Damage to any of these creates errors in the body’s biochemistry.

The international commission on radiation protection(ICRP) has created that beautiful model of a Caucasian male, 20-30 years of age, weighing 70 kg and being 170cm tall, the so-called ‘Reference Man’, to establish a safe limit of exposure.

To neglect assessing the specific effects of tritium on women, on infants and even fetuses should ring alarm bells!

With the nuclear establishment having accepted the ICRP’s recommendations it is no wonder that the CNSC assures the public that there is nothing to worry about exposure to tritium.In their Fact Sheet dated Dec. 2007 it claims that most of it leaves the body as tritiated water in urine, breath moisture and perspiration. It mentions that a small amount becomes organically bound with an average 40-day half-life.

In a study published in the February issue of the Science For Democratic Action magazine by the Institute for Energy and Environmental Research (IEER) the authors point to the fact that Organically Bound Tritium(OBT) is retained in the human body longer than HTO. They state “For certain molecules with very slow turnover rates, this [retention] time can grow to 280 to 550 days.” They continue “ The longer times of OBT are of particular concern if the tritium is incorporated into tissues such as neurons (the main cells of the nervous systems) or oocytes (immature egg cells). “Considering that ova are formed once per lifetime, the effects of radiation on the reproductive system of female fetuses, and the possible effects on the children of females irradiated in the womb, could be significant.”

The CNSC Fact Sheet, though, in Q5 states categorically “ There is no evidence of health effect [of tritium] at doses below 100 mSv.” And further” The general population in Canada is not at risk from tritium intake.”

In November 2007 the Advisory Group on Ionising Radiation (AGIR, U.K.) published a report of their review of the risk of exposure to tritium, and suggested that the ICRP increase its tritium radiation weighting factor from 1 to 2 based on published laboratory evidence.

Still those nuclear experts are not convinced by the latest studies that low doses of tritium cause adverse health effects.

A comment sheet by Health Canada titled Radiological Characteristics of Drinking Water modified as recently as July 2006, seems to vastly downplay the introduction of radionuclides from nuclear plants into the environment. It dwells on the natural background levels from radioactive elements in the Earth’s crust and from cosmic radiation together contributing more than 98% of the human radiation dose, excluding medical exposures. Then it adds the fall-out from nuclear weapons tests to argue that emissions from nuclear reactors are a potential source of artificial radionuclides in the environment.

This Health Canada publication needs a significant re-write since it contains inaccuracies like the location of the Bruce nuclear plant, statements on the containment of virtually all fission products until radioactive decay renders them stable, and the misleading level for the design dose limit for Canadian nuclear reactors. Information gaps like this put the accuracy of all the other information in doubt!

The Standards and Guidelines for Tritium in Drinking Water (INFO-0766), a document released by the CNSC in January 2008, defends the dose limits recommended by the ICRP and the WHO. It also states that regarding younger age groups the Dose Conversion Factors (DCF) used for adults do not lead to significant higher dose criteria due to smaller amounts of water consumed. Therefore the WHO’s Guideline Reference Level of 0.1 mSv per year over a one year consumption is a conservative level to be used for ALL AGE GROUPS (pg. 4).(!). Do they ever take the much faster metabolism of babies and infants into account?

The document then compares the international limits for tritium in drinking water. There is quite a variance, with countries operating Candu reactors like China, Korea and Argentina having no limits, while countries in the European Union are bound by the European Directive Setting of 100Bq/l. The U.S. has a 740 Bq/l limit, Switzerland 10,000 and Finland 30,000.

I guess it is no secret that Candu reactors release magnitudes of tritium compared to other designs as the INFO-0766 sheet refers to in its introduction, because of the heavy water used in their moderator.

Is this a reason or excuse to keep Ontario’s drinking water dose limits exorbitantly high?

Well, we only have to look to the nuclear regulator’s ALARA principle for radiation protection. It calls for exposures to be kept As Low As Reasonably Achievable with the caveat ‘economic and social factors taken into account.’ Where do we draw the line between the industry’s and the public’s health?

And now to answer the third question: As far back as 1994 The Advisory Committee on Environmental Standards (ACES) recommended a drastic lowering of the Ontario Drinking Water Standard, arguing that due to tritium being a carcinogen and the many uncertainties in the risk assessments, an immediate level of 100 Bq/l to be adopted , lowering it to 20 over the next 5 years.

In the 9th Biennial Report of the IJC released in 1997, the Commission sent this warning “The [Nuclear] Taskforce concluded that the [dose assessment] models used to derive the allowable discharges have limited relationship to the ecological cycling of radionuclides…” “The models make specific assumptions about the transfer of radioactivity from radionuclides in other biological compartments and the movement of radionuclides through the food web.” “ these radionuclides have long half-lives … and present long-term toxicological and ecological problems.”

Tritium is specifically mentioned as one of five radionuclides which merit further studies and reports.

In 2003 the European Committee on Radiation Risk (ECCR), investigating the health effects of ionizing radiation at low doses, severely criticized the ICRP model for setting dose limits which have not arisen out of accepted scientific methods.

The 2005 report on Biological Effects Of Ionizing Radiation (BEIR VII) by the national Academy of Sciences also takes issue with the ICRP model failing to protect women and very small children. It underlines the risk of any exposure to radiation producing a corresponding increase in cancer risk.

Despite the weight and prevalence of those findings these high- profile expert studies have not moved the CNSC to strengthen the standards for radiation exposures. It mirrors the long delay by the AECB to adopt ICRP 60 recommendations which were introduced 8 years earlier and had been incorporated in most countries’ radiation protection regulations, lowering public exposure limits from 5 to 1 mSv per year.

Are we going along with protecting the health of the nuclear industry or are we demanding that the regulator and the government, in this case the Ontario government, act to accept the overwhelming evidence? There is a growing list of evidence that demonstrates that low-level beta particles, like those emitted by tritium, are often much more effective at causing harm than currently assumed by regulations which are supposed to protect the public and especially the most vulnerable like babies and not-yet-born.

Other jurisdictions like California and Colorado are leaders in recognizing the dire need to significantly lower exposure limits to 400 picoCuries (14.8 Bq/l) per litre!

The CNSC explains those standards as based solely on scientific and public health considerations, without regard to economic cost or technical feasibility in their INFO-0766 (pg. A12).

We have waited long enough for the recommendations of the ACES Committee to be implemented – 14 long years, with many people, especially children, suffering the effects of those continuous exposures.

WE DEMAND THAT THE 100 BEQUEREL PER LITRE LIMIT FOR ONTARIO’S DRINKING WATER BE IMPOSED ON INDUSTRY NOW, AND THE CALIFORNIA 14.8 BEQUEREL PER LITRE PHASED IN BY 2012, BY WHICH TIME ALL OF ONTARIO'S AGING REACTORS SHOULD BE TAKEN OFF LINE!!

Please seriously consider these strong recommendations under the guidance of the PRECAUTIONARY PRINCIPLE!