Nuclear Awareness ProjectP.O. Box 104Uxbridge, Ontario, Canada L9P 1M6tel/fax: 905-852-0571October 22, 1999Manager, Drinking Water StandardsStandards Development Branch125 Resources RoadEtobicoke, ON M9P 3V6By fax -> 416-235-6059 (original via Canada Post)Re: EBR Registry # PA9E0006 -- Proposal to Adopt the Canadian Drinking WaterQuality Guidelines for Radiological Characteristics as an Ontario Drinking Water Objective for RadionuclidesTo whom it may concern,I am writing to provide comments on the above noted matter on behalf of Nuclear Awareness Project, a citizens environment organization. Our local chapter, Durham Nuclear Awareness (DNA), was involved in consultations regarding the expansion of the Ajax Water Supply Plant in the early 1990s. At that time DNA raised concerns about tritium contamination of the water supply due to emissions from the Pickering nuclear generating station. DNA also took part in the subsequent consultations conducted by the provincial Advisory Committee on Environmental Standards (ACES) which resulted in the May 1994 report to the Ontario Minister of Environment and Energy entitled "A Standard for Tritium". The ACES report highlighted the double standard which places non-radioactive hazardous materials under stricter limits than radioactive materials. ACES recommended that the standard for tritium in drinking water be set at 100 becquerels per litre (bq/l), and that the standard be further reduced to 20 bq/l after 5 years. Nuclear Awareness Project supports this recommendation and requests that the 20 bq/l level be established as the Ontario Drinking Water Objective for tritium. Similarly, the other levels being proposed as Ontario Drinking Water Objectives for radionuclides should be lowered proportionally to eliminate this double standard for radioactive contamination in drinking water. We followed with interest the work of 'Joint Working Group 6' (JWG-6) set up to "examine the similarities, disparities and inconsistencies" in regulating these hazards. The 18th and final draft of the JWG-6 report entitled: "Assessment and Management of Cancer Risks from Radiological and Chemical Hazards" recommended against harmonizing these regulations because of a lack of agreement on what acceptable risk for the public should be set at. By endorsing that status quo in regulation, the working group members have failed to serve the interests of all Canadians who are exposed to radioactive industrial pollution. >From our perspective as a public interest organization, the double standard which allows extra risk to the public from exposure to radioactive materials, as compared to other hazardous substances, is unacceptable and should be eliminated in the process of setting the Ontario Drinking Water Objectives for radioactive materials. This double standard is not warranted because there are pollution control measures which could and should be taken by the polluters to reduce radioactive pollution. The cost of these measures must be included in the cost of their respective products (i.e. uranium concentrates from mills and refineries, electricity and radioisotopes from reactors, the cost of research time at research reactors, etc.) These radioactive substances are, after all, known carcinogens, and the current Policy Proposal under consideration states: "The primary purpose of Ontario Drinking Water Objectives is to protect public health." We wish to make special note of the fact that the International Joint Commission (IJC) has, since 1994 recommended that radionuclides with a half life greater than six months be included in the definition of persistent toxic substances under the Great Lakes Water Quality Agreement, and that strategies for virtual elimination of these pollutants from waste streams be implemented. (Recommendation 12 to federal and state/provincial governments, 7th Biennial Report, Feb. 1994.) In response to the ACES recommendations to tighten the tritium standard, Ontario Hydro argued at the time that expensive tritium pollution control equipment would be required at the Pickering and Bruce nuclear stations in order to meet the tighter standard. However, it is important to note that since the closure of the oldest four reactors at each of these sites at the end of 1997, tritium emissions to water have dropped to a level where 20 becquerels of tritium per litre (bq/l) of drinking water is no longer routinely exceeded (on a weekly average basis) at either the Ajax or Port Elgin water supply plants. The attached graphs from the "Annual Summary and Assessment of Environmental Radiological Data" published by Ontario Power Generation (formerly Ontario Hydro) show that in 1997 the Ajax plant was at or over the 20 bq/l level for tritium in drinking water for 11 weeks (the highest weekly average being 40 bq/l), while in 1998, the 20 bq/l level was hit or exceeded for only 3 weeks (with the highest weekly average being 25). Similarly, in 1997 Port Elgin's drinking water supply was at or over the 20 bq/l level for tritium for 27 weeks (the highest weekly average being over 70 bq/l), and in 1998 the 20 bq/l level was barely exceeded for just 2 weeks on average. Data for hourly peak levels is not presented in these annual reports. One can conclude that the closure of the older Pickering A and Bruce A stations has contributed to a drastic cut in tritium emissions to water at those two locations. Restart of these stations should be contingent on the addition of suitable pollution control equipment, and indeed, Ontario Power Generation has announced plans to retrofit the four Pickering A reactors with improved tritium pollution control equipment if approval to restart the station is granted. Of all the radio nuclides emitted from nuclear industry facilities, tritium pollution is the only example we are aware of where the nuclear industry has argued that a tighter standard for radioactive materials (in line with the standards used for non- radioactive materials in terms of public risk from exposure) will mean added expense to comply. If the Ministry of Environment is aware of any other examples, these cases should be publicly examined to determine if the pollution in question can be reduced through the use of pollution control equipment. We understand that to remove this double standard in the case of the Ontario Drinking Water Objectives would set an important precedent and cause the nuclear industry to adjust some current practices in order to comply. It is our position that this tightening of standards for exposure to radioactive materials is long overdue, and that it would be appropriate for the province to set this important precedent in order to help protect public health and the environment. Thank you for your consideration of our comments. Sincerely,Irene Kock

Title:Comments by Nuclear Awareness Project on Proposed Guideline for Tritium in Drinking Water
Resource Type:Letter, Response to Consultation
# of Pages:1
Date authored:October 22, 1999
Author/s:Irene Kock
Author Organization:Nuclear Awareness Project