1.  Transcript of the oral presentation on January 17th by the

2.  Physicians for Global Survival at the Cameco Fuel Conversation Facility Liscence Renewal Hearings in Port Hope

DR. HARVEY: Thank you to the Commission  for allowing me this opportunity to speak. My name is Dr. Linda Harvey and I’m representing Physicians for Global  Survival. I’ve spoken several times in the past at CNSC hearings on my own initiative. I’m now working with this organization. PGS is very aware that the radioactive contamination from all phases of the nuclear industry is a global problem which has medical consequences. PGS is concerned that the increasing dissemination of radioactive material is making many areas unsafe and unfit for human use.  

From our perspective this is exactly what is taking place in Port Hope. Over two million cubic meters of low level radioactive waste lie distributed  through the town in ravines, in parks, in schoolyards and under buildings.  Levels of gamma radiation in several parts of downtown including the water works area, CN/CP Viaduct area and Alexander Street Ravine have been recorded at 100 microRem per hour; this is from the government survey in 1994. This is sufficient to deliver a yearly dose of 8.76 millisieverts per year which is far in excess of the 1  millisievert per year allowed for public exposure from  nuclear materials. This is unacceptable. Most of this waste is residue from the operation of the current licensee, Cameco, and its  predecessor Eldorado Nuclear.   

It is interesting to note that it was known in 1931, shortly before the Eldorado/Cameco facility opened, that the radioactive ores coming from Northern  Ontario were deadly and should be handled with extreme caution in a carefully monitored workplace. The situation that has been arise in Port Hope represents a regulatory.  We have grave concerns that  industry nor the regulator is competent to facility in a safe and responsible manner. It might be important to pause here and look at the question of standards. Just because something is within current standards does not mean it is safe. It may simply mean that certain hazards associated with that material are not known or were not addressed in setting the standard.   

In the case of radioactive materials and radiation, the current allowable standard is allowed failure. neither the manage this  millisievert per year for the public and 20 millisieverts per year for the nuclear industry or 105 years. Is this protective? According to guidelines from the International Commission on Radiological Protection, the cancer risk from radiation  exposure is about -- is 0.04 cases per seivert. This is a fairly conservative estimate. Over a 40-year career at 20 millisieverts per year a worker will be exposed to 800 millisieverts or   0.8 sieverts. His odds of getting cancer are then 0.08 times 0.04 or 0.032. That is approximately three in a  hundred. So if a hundred workers are so exposed, three of them will be expected to get cancer. The nuclear industry in Canada employs,  I’ve been told, approximately 70,000 workers. Over a lifetime in the industry, 70,000 times 0.032 or 2,240 of  them will be expected to get cancer as a result of this level exposure.

Clearly this standard is not protective. In reality, most nuclear workers are not exposed to  anywhere near this amount of radiation and relatively few  of them get sick, but this exposure is allowed. Clearly this standard is inappropriate. The new uranium and air standard of 0.03 micrograms per cubic metre is also not protective. According to material published in the Canadian Council of Ministers of the Environment in 2007, soil levels of uranium can increase as a result of airborne deposition. In order to maintain a level they consider safe for  residential soil, levels in air should not exceed 0.002  micrograms per cubic metre. More detail in this calculation is given in our written submission.  It is problematical whether Cameco can get  their uranium emissions below 0.002 micrograms per cubic metre judging from the past numbers that I have available  to me.

Hiding behind the assumption that because something is within the standard it is safe is indefensible.  Is there any evidence that there has been  harm done to the residents of Port Hope to date through exposures considered safe by the nuclear industry? This subject is treated in more detail in our written submission.  

In summary, there are statistically significant elevations of cancer of the trachea, bronchus and lung, pharynx and sinuses in Port Hope as compared to  Ontario for the period 1971 to 1996. These are all bodily structures which are in the path of oncoming ingoing airborne contamination.  

These statistics are presented in CNSC synthesis report “Understanding Health Studies and Risk Assessments” conducted in the Port Hope Community from the 1950s to the present, which was put out in April 2009. The authors conclude against scientific justification that there has been no harm to the citizens of Port Hope. In fact, there is a very real possibility that people in Port  Hope have fallen ill as a result of exposures created by the nuclear industry.  It is imperative to apply the precautionary principle and the prevention of future illness from the continued emissions and waste generation of the Cameco  facility. This is the issue which this licence hearing should be addressing above all others. This issue is not even mentioned in most of the material we have reviewed on the matter. It is our concern that the CNSC has failed to appreciate the significance of its own medical data on this population. 

Far more concerning than cancer is the issue of genetic damage to reproductive cells which can be carried forward through generations. This damage is not  reversible and combined with ongoing exposures in an  increasingly contaminated world is cumulative. This  damage may take many generations to manifest itself in visible disease or deformity and by the time it does,  considerable deterioration will have occurred in the human  genome. 

Ongoing genetic deterioration can persist even after radiation exposure has ceased. Genetic instability in cultured cells has been shown to persist 25 to 50 population doublings after a brief irradiation with x-rays, gamma rays or alpha particles. This is  characterized by increases in spontaneous mutation rates, ongoing chromosomal rearrangements, and possibly increased sensitivity to other external mutagens. There are a number of possible mechanisms  for this phenomenon including damage to the systems regulating DNA replication or to the DNA repair  capabilities.  

Many of these effects can be seen in the  test tube at doses as low as 1.6 to 10 milligray; that’s 32 to 200 millisieverts of alpha radiation or 50 milligray or 50 millisieverts of low LET radiation.  These doses are in a range which might be  relevant to the Port Hope population and/or Cameco employees. Whereas, it is not possible to extrapolate directly from the in vitro data to living humans, we must recognize that we are made of rather similar biochemical  material.   

Is there any evidence that these effects do occur in higher organisms and in humans? Yes, there is. Scientists working in the contaminated territories around Chernobyl report on instances in which rates of chromosomal aberrations, mutations, embryonic death continue to increase in voles, mice, and songbirds long after ambient radiation levels are starting to decrease. Offspring of many of these organisms reared away from the contaminations continue to deteriorate genetically.