It seems strange, but throughout the approval process for the Bruce Campus DGR, there was no broad survey of the health of local residents to use as a baseline for assessing health effects of the proposed DGR. Indeed, as many of the citizen reviewers of the proposed DGR have pointed out, there is no unified presentation of health issues anywhere in the proposal’s supporting documents.
This is strange because, of course, concern over human health is a major reason for scrutiny of the approval process in the first place. This lack of data has long been a cause for concern, as is the regulators’ use of this lack to support their claims of the plants’ safety. Even though the precautionary principle would require proponents of the Bruce station to have the data in order to prove that no harm has occurred, the regulators and proponents have instead taken the opposite position — that the lack of evidence means that concerned citizens can’t show that anything is wrong, and thus there are no grounds for objection. This led the AECB (Canada’s older regulatory board) to say that
“the observed 40% excess in childhood leukemias was ‘in fact, most likely due to chance.'”
[However,] one important means of assessing trends over time is to compare leukemia deaths before nuclear power plant operation with deaths after. The authors of the AECB study carried out this work for the Pickering nuclear station, but not the Bruce station….
For the comparison that was done… the leukemia rate before operations was essentially the same as expected.
Thus, there is no evidence of an increase in childhood leukemia rates before the activation of the two plants. However, the study data shows a significant excess in childhood leukemias after operations began.
– Hoel affidavit, p.6
It thus behooves the government and proponent, in support of the currently proposed DGR expanding the Bruce nuclear campus, to at least gather baseline health data now, so we would be able to tell how the proposed project changes the health profile of the surrounding area. It is ironic that the regulatory approval of the DGR leans so much on the practice of adaptive management, where the proponent is supposed to keep track of whether things are going wrong and adapt its activities accordingly. But at the same time, it is refusing (and in fact actively opposing) the gathering of data that would let it know if the health situation near the plant is deteriorating.
We follow up here on some recent correspondence on the issue, giving more information on the basic issues:
Dec. 8, 2015
Dr. Hazel Lynn, Medical Officer of Health
Grey Bruce Health Unit
101 17th St. E.
Owen Sound, ON
N4K 0A5
Dear Dr. Lynn:
On Nov. 15, 2015, I responded to your acknowledgement letter of Nov. 1 with a letter by email describing our concerns and seeking clarification:
“Just a note to acknowledge your feedback and thank you for your work on healthier communities. Unfortunately we are not in a position to engage in unfunded studies at this time of fiscal uncertainty. H Lynn”
1. Our request was not for your office to fund this study. It was a request to acknowledge the fact that this database is missing;
2. to acknowledge that there are methodologies available to acquire this data; and
3. to recognise that having this data will allow your office, as well as any other office, the ability to make scientifically valid statements about the health of the community that comprises the Local Study Area (LSA) for both Bruce Power’s operations and OPG’s proposed DGR.
Thank you,
Eugene
To date, I have not had a response from you and hope that this is merely inadvertent.
Standards used
You have stated to me that the Grey-Bruce Public Health Unit accepts World Health Organisation (WHO) standards of health, as does Ontario Power Generation (OPG) in its Environmental Impact Statement (EIS) for the Deep Geologic Repository (DGR). Stress is an important characteristic of sound health and one of your roles would be to engage in sound, policy-making decisions that serve to reduce the stress of the members of the community you serve. You have heard that the two public interest groups who represent the interests of Inverhuron residents support our proposal for a community health survey. We are a community that is shadowed, and perhaps overshadowed, by the nuclear industry here and, as time progresses, it appears to many of our members that morbidity has increased. We are, of course, aging and that is certainly a factor. But we have also been exposed to ionising radiation, as well as other toxic chemicals emitted by this industry into our atmosphere, soil, food and water.
Your office relies on administrative or regulatory values that accept certain permitted concentrations of ionising radiation as if these are safe levels of concentration. These are then compared to background levels.
Is all radiation equal?
While none of us can avoid the external impacts of solar radiation, this is not to say that these background levels are safe. Indeed, while your office’s own website cautions that these are not safe levels (advising us to wear sunscreen appropriate to the current conditions when outdoors), we have no protection from the external and especially the internal emitters of alpha, beta and gamma particles to which we are chronically exposed by the operations at the Bruce Nuclear Generating Station. Scientific bodies, including government-sanctioned ones such as CERRIES (Great Britain) and KiKK (European Union), have cautioned that internal emitters (such as alpha and beta particles that affect us at the cellular level when we breathe them or eat them in our water or food) appear to have radically different impacts on cellular health than external ones. This is especially so when the exposures are chronic ones that happen all the time, just as happens here in Inverhuron. You, in your response to me, tout the Canadian Nuclear Safety Commission’s (CNSC’s) RADICON study as if it were definitive. Nonetheless, you also heard Dr. Thompson of the CNSC state during the EIS hearings when you were present that neither she nor the CNSC would support having this study peer-reviewed by independent experts who would be chosen by LSA residents. While we seek quantifiable data, we are offered only qualitative data. We seek evidence that can be verified scientifically. Instead we receive opinion founded on belief and hope, opinion that assuredly allows the industry to function and operate as if everything was fine. We all hope that this is true and that this hope can, instead, be quantified in a way that will allow us to test the claims with scientific methods that apply to our community instead of to the evidence given by some broad geographic region as is currently used. In any event, it is the data from the broad geographic region of southwestern Ontario that you quoted during your testimony at the EIS Hearings in support of the position you presented to the Joint Review Panel (JRP).
Our report, which we have sent you twice, demonstrates that there are reasonable and viable methodologies that would allow for such an analysis. While you have stated a preference for engaging in a general happiness survey of the Grey-Bruce region as a whole, your office is not prepared to support financially the mechanisms required to acquire evidenced-based data that will allow us to determine the nature of the health impacts, if any, on LSA resident stakeholders from the nuclear industry here.
We haven’t asked for your office’s financial support, but merely to support the clear benefit that having such data could provide in terms of being able to make statements about the health of LSA residents. Any such statements could then be tested using scientific methods instead of relying primarily on best guesses and models. We continue to believe that the emitters of these toxic substances, Bruce Power and OPG, ought to be the responsible parties for funding.
A picture is worth a thousand words
We receive annual summary reports about the nature and quantities of ionising radiation and their concentrations in the general region, with a magnifying glass over these data as if to suggest that these are not really harmful when compared to background radiation. However, your office already recognises that background radiation is toxic and harmful to people who are exposed to it. You do not indicate the scientifically-verifiable reasons your office has to claim that additional radiological exposures will provide a net benefit to LSA resident stakeholders. This is especially true of the internal emitters in contrast to solar and cosmic radiation that affects us externally. Background radiation and alpha and beta particles might not be directly comparable.
Consider, for example, the following graph:
Bruce NGS stack emissions
How does your office explain that these exposures are a net benefit to innocent members of the public and have neither caused harm nor will in the future cause harm due to cellular damage? If these additional iodine isotopes are a net benefit, why has the CNSC mandated that potassium iodine pills be distributed to all residential stakeholders within a radius of the Bruce Nuclear Power station to be used in the event of an iodine ‘spill’ at the Bruce? Would a spike like this be considered such a spill? Does your office have standards of disclosure such that resident stakeholders will be protected or are all decisions about these matters left to Bruce Power’s discretion?
Faith-based vs. evidence-based decisions
We are not going away and this issue will not be going away. OPG has proposed adding significantly to our toxic load here in the LSA region but expresses the opinion that these additions will not be harmful to us. Bruce Power has stated that it can operate these reactors beyond the manufacturer’s recommended life-time of operations for the pressure tubes but maintains that this will not be detrimental to our community’s health. With the announcement on Dec. 3, 2015, Bruce Power will now be operating these reactors to 2060-2070. Pressure tubes that had a manufacturer’s life-expectancy of 210,000 Effective Full Production Hours (EFPH) have been extended indefinitely. Bruce B reactors will now run in some cases to more than 275,000 EFPH, even though it has only been granted a licence extension to 247,000 EFPH. That is 31% more than the recommended life-time of operations for these pressure tubes. Bruce Power maintains it can operate these reactors safely until then but, without a baseline database of the state of health of the LSA residents, it is not and will not be possible to quantify this unsubstantiated claim. With the extended operations, there will be an even greater quantity of low and intermediate level nuclear wastes for the DGR and the rock pile, which is already expected to contain numerous highly toxic chemicals and isotopes and which will grow even larger, will surpass the currently revised estimate of more than 140’ in height and cover more than 44 acres in surface area as OPG reported in the second phase of the Hearings for the DGR.
Your office appears to accept these assertions as if they were true when neither your office, nor Bruce Power nor OPG can or will provide evidence that this is so. In any event it will be stated, as you did during the EIS for the DGR, that our population base is too small to be able to make these determinations on the basis of the broadly-based epidemiological approaches normally used by large studies.
Anna Tilman and I have provided an outline as to how these baseline data might be acquired and provided examples where communities, sometimes in opposition to Public Health offices, have managed to demonstrate through their methodologies that there have been impacts when none was thought to have existed.
Our community is concerned about the impacts here from existing and future operations of this, our local nuclear industry. We do not accept that qualitative data will do or is acceptable in lieu of quantitative data.
Morbidity and mortality continues in Inverhuron
Another neighbour died of throat cancer last week. Like the previous neighbour, neither was a smoker and each spent a considerable amount of time outdoors. Prostate cancer seems to be rampant here as is chronic fatigue syndrome and heart disease. Diabetes is also prevalent and so is mental illness. Are these concentrations merely representative of our society as a whole or are they higher here? We don’t know and this fact alone adds to our communal anxiety, something your office accepts as an adverse health effect in and of itself.
That ambiguity can be dispelled and needs to be dispelled. We know how to dispel it and with the support of your office we can all work to making this, the LSA region, a healthier community, a task you have thanked me for bringing to the forefront of these discussions. I hope, and indeed we all hope, that your office becomes a partner in this pursuit.
Thank you,
Eugene Bourgeois