Back


Unresolved concerns of the people of Port Hope
(5 April 2005)

Prepared by Families Against Radiation Exposure and
Port Hope Community Health Concerns Committee
at the request of Paul Macklin, MP

We believe that the screening process used by the Canadian Nuclear Safety Commission to consider Cameco Corporation’s application for a license to blend enriched uranium (SEU) is not adequate to deal with the following outstanding critical issues facing the people of Port Hope.

Buffer Zone

The Canadian Nuclear Safety Commission and Cameco have repeatedly stated that there has never been a requirement for a buffer zone around a facility like Port Hope's.

However, the following statement was found on page 1-1 when reviewing a document from 1976 titled "Evaluation of Potential Sites for a New Uranium Refinery in Ontario:"

"Because they are by definition nuclear facilities, UF6 plants come under the jurisdiction of the Atomic Energy Control Board (AECB). The AECB requires that new UF6 plants conform to the same philosophy of licensing and safety requirements as nuclear power plants. While this means that the UF6 plant must be designed in accordance with a number of safety criteria and principles, the one of primary significance in site selection is the recommendation for an Exclusion Zone of 1,000 meters radius. No permanent habitation is permitted in the Exclusion Zone."

The 1978 document titled "Environmental Impact Statement for a UF6 Refinery in Hope Township" states: "A major factor in selecting specific refinery sites is the accepted industrial practice of placing a 'buffer zone' around nuclear facilities as required by the federal government’s regulatory agency, the Atomic Energy Control Board."

None of the 14 sites that were evaluated in 1976 met the AECB and Eldorado’s criteria, so the nuclear regulator just changed the criteria and said it was safe to put in the middle of town.

UF6 plants require such a buffer zone because of the dangerous chemicals and materials they use and this is not limited to uranium and other radioactive isotopes. The most hazardous non-radioactive material they use is hydrofluoric acid.

The Sequoyah Fuels UF6 plant in Oklahoma had only one person living within 800 meters of the facility and less than 20 residences within 3 kilometres. The Padukah and Piketon enrichment plants in the United States, which use UF6 as feedstock, sit in the middle of 3,400 and 3,700 acres respectively. In other words, they have a 2 kilometre buffer around their plants.

Every other nuclear fuel cycle facility in North America has a buffer zone. So does the British Nuclear Fuels site at Springfields, near Sussex, which Cameco recently contracted to supply it with 6,000 tonnes a year of UF6. That site, which produces less of that material than the Port Hope plant, sits on 211 acres.

Suggested action: In view of the memorandum of understanding signed by both Environment Canada and the Canadian Nuclear Safety Commission, the federal environment ministry should be asked to investigate and report publicly on the history of the disappearing buffer zone for Port Hope. CNSC and Environment Canada should enter into a public discussion on this important matter before Cameco's Environmental Assessment report on the proposed SEU project is even considered.

Hydrofluoric Acid: Transportation concerns

Hydrofluoric acid is the most dangerous commonly used industrial chemical there is. Cameco uses more hydrofluoric acid than any other company in Canada. During full production, it consumes about a tanker truck full every day in Port Hope. Containers of hydrofluoric acid are transported through residential streets in town.

Cameco uses it to produce uranium hexafluoride (UF6). According to the International Atomic Energy Agency, an accident involving UF6 could result in "dangerous concentrations of both uranium and hydrofluoric acid and may also cause area contamination of several square kilometres."

The best source of information on the hazards associated with the transport of UF6 is The Hex Connection by Miles Goldstick ISBN 91-576-4440-3. Jonathan Ward, the director of toxicology at the University of Texas, says: "Highly toxic hydrofluoric acid has many acute consequences for human health, as well as the ability to kill people on the spot."

Hydrofluoric acid is a known quantity to some terrorists, according to Global Options, a security firm in Washington D.C.

Hydrofluoric acid accidents occur frequently. The National (U.S.) Response Center’s Emergency Response Notification System reported 269 incidents involving hydrofluoric acid between 1992 and 2002. Many refineries in the United States are finding substitute acids to use in production.

A UF6 container similar to those used by Cameco ruptured at the Oklahoma UF6 plant in 1986. According to an article from Health International: "A plume of toxic gas that killed one worker and put 43 others into hospital drifted up to 29 kilometers from a nuclear fuels plant before dispersing." The container that ruptured in Oklahoma was purchased from Eldorado in Port Hope four months before the accident occurred.

On October 30, 1987, a crane at Marathon Oil’s Texas City refinery dropped its load on a storage tank, rupturing a pipe and releasing 30,000 pounds of hydrofluoric acid. The resulting vapor cloud sent 1,037 people to the hospital suffering from respiratory problems and skin rashes and forced 3,000 residents out of their homes for three days. According to Ronald Koopman of Lawrence Livermore National Laboratory: "There were houses right up against the fence. The only thing that saved people was that the [hydrofluoric acid] plume shot 200 feet up in the air, and it went about 900 meters downwind before it actually came down into the neighborhood. If it had squirted out sideways, it would have killed hundreds, if not thousands."

Simply stated, if one of the UF6 containers or a tanker truck of hydrofluoric acid ruptured at the Cameco plant with the wind blowing from the south, the majority of Port Hope residents in the valley would be dead or injured in a matter of minutes.

There was a mock accident set up in Port Hope last fall with a leak of hydrofluoric acid from a tanker truck. The analysis of the exercise concluded that local emergency personnel were not prepared to deal with a hydrofluoric acid spill.

Fire fighting manuals require a standoff distance of 300 meters for a hydrofluoric acid spill or UF6 accident until fully trained staff are available. This raises the question of whether there is a common law duty to notify everyone on title within 300 meters of the Cameco facility and transportation routes. We understand that Port Hope received a legal opinion relating to Low Level Radioactive Waste that caused municipal council to require notification on title for any homes built or sold in the entire community, not just homes within 1,000 meters of the LLRW storage site. What will such notification relating to Cameco, hydrofluoric acid, UF6 and LEU and SEU do to property values?

The CNSC has opted out of any responsibility in these areas and the Cameco EA states that it is the responsibility of the municipality for all roads and transportation in and out of the municipality.

Similarly, is it the responsibility of vendors, their agents and lawyers to notify all clients in areas that might be exposed to nuclear related accidents that they have no home liability insurance for any accident or resulting damages from such an accident, including the costs of evacuation?

Suggested action: In view of the issues listed, Transport Canada should be asked to review and report publicly on all safety and legal liabilities associated with the transport of hazardous substances from Cameco and Zircatec through the streets of Port Hope and neighbouring communities.

Forgiveable deadlines

A comparison of two CNSC documents – the Feb. 18, 2002, license renewal of Cameco, and the Dec. 20, 2004, mid-term review – shows a pattern of forgiveable deadlines and non-compliance. The detailed comparison (attached) was submitted to the CNSC on Feb. 23 and was not challenged. It shows that the company is not compliant with the National Fire Code of 1995, and will miss its latest promise to be fully compliant by more than two years. Instead of a warning or censure, the CNSC staff says Cameco is making “acceptable progress.”

Our comparison shows that the CNSC staff is still reviewing the company’s Emergency Preparedness and Response Manual more than a year and a half after it was submitted. It shows that CNSC inspections of Cameco have turned up some deficiencies under the Nuclear Safety and Control Act, but those are not even described.

Families Against Radiation Exposure argued that the CNSC should not even consider Cameco’s application to handle enriched uranium until its existing plant is fully compliant. The Commission has not even responded to our suggestion.

Suggested action: We would like you, as our member of Parliament, to write a letter to the CNSC and to Environment Canada expressing the opinion that firm deadlines should be set for compliance, and this should be achieved before any decision is made on SEU.

Emergency Concerns

Thanks to citizen research and intervention, the Canadian Nuclear Safety Commission hearings on Feb. 23, 2005 revealed:

1. That we have no one in Port Hope capable of fighting a radiological fire. (It would take crews from Toronto 1.5 to 3 hours to arrive in Port Hope)

2. That we have no comprehensive system in place to warn residents in case of an accident.

3. That there is no evacuation plan in place.

The CNSC staff made no mention of these deficiencies in its mid-term license report on Cameco, even though they received a copy of a letter from the Port Hope fire chief last year alerting them that his volunteer force was not equipped to fight any fire involving hazardous materials inside Cameco or Zircatec. Cameco admitted at the February hearings that it did not have the ability to fight such a fire either.

This situation is obviously critical. It is exacerbated by the continued lack of compliance of the 70-year-old plant with the National Fire Code. According to the mid-term license report: “In January 2004, CNSC staff performed an inspection of Cameco’s facility for compliance with the National Fire Code of Canada. During the inspection, deficiencies were found in the areas of storage of combustible liquids/materials, fire separations and fire doors, ventilation, electrical devices/wiring and fire equipment maintenance." It said the company has a plan to correct the deficiencies sometime in 2005. The National Fire Code of Canada dates from 1995, and there is no evidence that Cameco has ever complied with it.

There seem to be critical communications problems between Cameco and Zircatec, on the one hand, and municipal authorities. In its presentation to the CNSC in February, the municipality had to formally request copies of the emergency response plans for the two facilities.

Despite having two nuclear facilities in Port Hope, we are not part of the Ontario emergency response plan, which mobilizes the resources of 13 Ontario ministries. This situation should be completely unacceptable to all parties.

Suggested action: Since the companies and the municipality seem to be unable to resolve these critical problems, or even to assure residents that a solution is imminent, we need some outside authority to work out a solution. Urgently.

Centre Pier Waste

There are currently 13,000 barrels of radioactive waste stored in the buildings on the Centre Pier at Port Hope harbour. The site sits next to the Port Hope Yacht Club.

In addition, there are 15,000 cubic metres of radioactive waste stored under tarps on the pier. This contaminated soil came from the west beach area during excavation for the town's new water treatment plant. When the local Low Level Radioactive Waste office was searching for a site to store it, Cameco stepped forward and offered its licensed storage site on the Centre Pier. The company and the LLRWM office made a joint application to the Canadian Nuclear Safety Commission, which appears to have approved it.

It will sit there for at least four or five years until it can be disposed of in a new low-level waste disposal site being built in the community. But there is a question of safety. The tarps covering the pile of waste on the pier blew off three times during high winds this past winter. It was revealed during the Feb. 23, 2005, Canadian Nuclear Safety Commission hearings that staff, when questioned by the commissioners, could not guarantee that storing the waste there was safe. Considering Port Hope’s history of flooding, this is an unacceptable situation.

In fact, the pier is owned by the Municipality of Port Hope and leased to Cameco. The company pays Port Hope $2,900 per year for leasing the 10 acres and 122,000 square feet of buildings on the pier. The lease runs out this June. Cameco and the municipality are currently negotiating a lease extension.

Suggested action: Environment Canada should investigate and publicly report on whether the storage of this toxic waste on the waterfront is safe and legal.

Human Exposure to Contaminants

There is broad scientific consensus that there is no “safe” level of radiation exposure and that human exposures to ionizing radiation should be minimized. There is mounting evidence, including from the Johns Hopkins Medical Centre, that chronic exposure to low-dose radiation is potentially very harmful to human cells, human health and our DNA. Obviously, a thorough and independent evaluation of the allowable levels of exposure to radioactive substances imposed on the people of Port Hope by the CNSC is required.

Because there is no buffer zone, the public in Port Hope is exposed daily to uranium particulate in air from both Cameco and Zircatec operations. We also experience uranium compounds, fluoride, ammonia, nitrates and trace arsenic. The danger to the people of Port Hope is that we are breathing low-soluble, long bio half-life radioactive particles into our lungs. It goes into the lymph glands and bones and irradiates cells, stem cells and DNA – the foundation genetic substances of the body and what we pass to our offspring.

We are also located on the shore of Lake Ontario and so have moisture which creates fog and smog which, in turn, creates a greater risk from particulate. There is no local weather monitoring equipment or smog alert system.

The CNSC sets “allowable levels of exposure” based on complicated theoretical calculations that plot average, estimated exposures. The levels are set according to the ALARA principle (as low as reasonably achievable for the companies); however, given that there have not been proper health studies of real people, no one can say, least of all the CNSC, that these allowable levels are not causing harm to people.

Cameco’s quarterly reports confirm that there are public areas where the levels of gamma radiation from its operations exceed even allowable levels. The CNSC excuses it, saying that people are not in the locations for long enough periods to be adversely affected. That is an opinion and should be treated as such. The fact is, those areas are not even secured by a fence.

In December, 2004, the Uranium Medical Research Centre detected levels of gamma radiation on the public sidewalk beside Cameco higher than those they detected in Iraq after use of depleted uranium in weapons by the U.S. and Britain. This area is used regularly by children, fishermen and other members of the public to reach the waterfront.

Suggested action: The federal government must step in and deal with this public health issue. It must recognize the science which demonstrates there is risk to us and act to protect us. The buffer zone issue must be dealt with to minimize the exposure of people to harmful substances. It is time to apply the precautionary principle to Port Hope.

In the interim, the chronic exceedances by Cameco must not be permitted. The public’s exposure to alpha-emitting nuclides and uranium compounds must be monitored:

$ An infrastructure of radiation detectors should be set up at key locations under the control of the municipality, paid for by Cameco and Zircatec.

$ Canada has no allowable uranium in air or water standards. They need to be set, based on scientific testing instead of theoretical modelling.

$ There should be public display (on-line, real time digital display) of the levels of radiation, expressed in Be/metres and Sv/hr.

$ Uranium isotope assays should be conducted monthly of the stack emissions and this information should be available on-line;

$ A database of the readings should be maintained and available on-line for public use.

$ In addition, weather monitoring equipment should be installed locally which would enable local smog reports and alerts.

Uranium in air

Cameco’s mid-term license review, dated December 20, 2004, states that “there are no federal or provincial established limits or guidelines for uranium in ambient air.”

The CNSC told a different story in its reasons for deciding to extend Cameco’s license for five years in 2002. It noted that the Ontario Ministry of Environment will publish a draft standard for acceptable levels of uranium in the air and soil later in 2002. “CNSC staff noted that the draft guidelines have been subjected to intensive public, government and scientific peer review.” They also noted “the ongoing co-operation of Cameco and CNSC staff in the Ministry of the Environment’s experiments on soils near Cameco’s Port Hope facility and in the development of the proposed air concentration standard.”

What is going on behind closed doors? Why did the scientifically-based uranium in air and soil standards never get published? What is the real explanation for the discontinuance of the MoE-Cameco soil studies? All we know is that, according to the CNSC, “Cameco conducted their own testing program in parallel with MoE (starting in 2002). Due to problems attributed to test methodology, the results obtained showed significant variability and both test programs were terminated .... CNSC staff considers the results obtained insufficiently conclusive for regulatory purposes.”

Suggested action: Environment Canada should be asked to consult with the Ontario Ministry of the Environment and report publicly on the reasons why no uranium in air or soil standards have been published. The report should include details of any direct communication the ministry has received from Cameco, Zircatec or the nuclear industry associationss.

Neutron Radiation

On December 11, 2004, staff of the Uranium Medical Research Centre detected neutron radiation emissions at a distance of 20 metres from a uranium transport trailer parked in a public area at Cameo’s Port Hope site. The area is completely accessible, used by fishermen and children en route to the beach area and a public spit at the mouth of the Ganaraska River. Similar transport trailers carrying UF6 manufactured at the facility regularly travel through the public streets of Port Hope. They are not regularly monitored for neutron radiation when leaving the site.

Neutrons are up to 20 times more dangerous than gamma radiation in transferring invisible cell-destroying ionizing particles into the human body. The U.S. Department of Health and Human Services lists neutron radiation as a known human carcinogen, saying it can cause many types of cancer including leukemia and cancers of the thyroid, breast, stomach, colon, ovaries and lungs. According to Cameco’s own web site, neutron radiation is normally found only inside nuclear reactors. It must be shielded by a metres of reinforced concrete to avoid harming humans.

We are not aware of any monitoring or reporting by Cameco or CNSC on neutron radiation in Port Hope connected to its operations. The presence of such radiation is not mentioned in any licensing, environmental or safety reports issued by the CNSC or Cameco. In response to our press release on this finding, Cameco admits it is aware of the neutron radiation it is trucking through our streets, beside our sidewalks, parking beside our children.

Suggested action: The CNSC needs to investigate this situation and take immediate action to protect the public. The people of Port Hope want to know how this situation has been allowed to happen and for how long. The fact that it took independent monitoring to disclose this to the public is alarming and a serious breach of the CNSC’s responsibility to protect workers and the public.

We want to know if Cameco has been reporting neutron radiation to the CNSC and wish to have copies of those reports.

We wish to know if CNSC has allowable levels for neutron exposure for the workers of these industries and the people of Port Hope. In other words, we want the public to have a full explanation of who has known about this, if it has been sanctioned by the CNSC, and what is being done about it.

Health studies

In 1979 the federal government committed between $4 million and $5 million for comprehensive health studies of Port Hope residents because of the discovery of radioactive and heavy metal contamination throughout the community. The volume of the waste still remaining in Port Hope is estimated at 3.5 million cubic metres by AECL, and a re-survey is planned which may well find additional volumes and locations.

The people of Port Hope are still waiting for the health studies commitment to be honoured. Independent statistical analysis of two preliminary federal studies released several years ago has shown elevated rates in Port Hope of incidence and mortality from diseases such as lung cancer, brain cancer, colon cancer, lip, nose and pharyngeal cancer, leukemia, non-Hodgkins lymphoma, and circulatory disease. The federal studies were only a partial first step; they did not include people who have moved away and they did not focus on special groups who were at particular risk. Considerably more investigation is required.

The Port Hope Community Health Concerns Committee has a steering committee in place of professionals to oversee implementation of additional work: follow-up on rates of specific diseases; cohort studies of specific populations who were at risk such as students of contaminated schools; a comprehensive community health survey; biological testing of people; a long-term monitoring and records program. These studies must be conducted independently and managed by the community.

The health concerns committee has begun a joint project with the Uranium Medical Research Centre (UMRC) which is donating its medical and research services for radio-biological testing of people. However funding is required for other costs, including laboratory analysis. A meeting was held with the Minister for Public Health, Carolyn Bennett, in November 2004 to discuss funding for Port Hope health studies.

Suggested action: We would appreciate your help in setting up a further meeting with minister Bennett to discuss the specifics of the UMRC-PHCHCC project as an important first step. The federal budget announced in February 2005 offers possibilities for public health funding to research human health effects of exposure to toxic substances.

Liability Insurance

The Canadian Nuclear Safety and Control Act stipulates that there must be $75 million in liability insurance on a nuclear fuel cycle facility.

Cameo currently carries $4 million in liability insurance on its facility, and Zircatec only carries $2 million. That means the taxpayers of Canada would cover the rest, up to the legislated ceiling of $75 million.

This is clearly inadequate to cover any radiological accident. In the United States, the insurance requirement was raised to $7 billion more than 10 years ago, and each U.S. nuclear facility must carry $63 million in insurance.

In the event of a nuclear accident, all homeowner policies are null and void. The Nuclear Liability Act takes away the right of citizens to sue for compensation. Rather, the government appoints members of a claims commission who decide how the maximum insurance of $75 million is to be doled out. The legislation also makes it difficult for anyone to launch a claim after three years of an accident. Victims of slow-developing cancer or genetic mutilations would likely find themselves not covered.

Suggested action: Natural Resources Canada administers the insurance provisions of the Nuclear Safety and Control Act. It should be urgently asked to review the ceiling in light of higher thresholds in place in the U.S. and elsewhere.

Decommissioning guarantees

Cameco's decommissioning plan is inconsistent with a legal agreement negotiated between the Canadian government, the Town of Port Hope and the former Hope Township, and the Municipality of Clarington.

Cameco's deposit to the Canadian Nuclear Safety Commission to cover all costs to decommission its current plant is only $33.8 million. It has offered to post another $1.9 million to dispose of additional waste produced by its proposed facility to blend enriched uranium. This amount of money only covers transportation costs to a local storage facility. Cameco's decommissioning plan states: "At some point in the future, the rest of Cameco's site will be decommissioned. The design philosophy incorporated in the local LLRW facility is that it will be reopened to accommodate wastes arising from the second phase of decommissioning

This is incorrect. The legal agreement for the disposal of low-level radioactive waste covers only waste produced before 1988, when Cameco took over the operations of Eldorado Nuclear, a crown corporation. A facility to house the 3.5 million cubic metres of pre-1988 waste is being planned on Baulch Road near Highway 401. Plans clearly show that, once the facility is closed in 2013, it will not be opened for future waste. There are guarantees that it will not become an ongoing dump site.

The local LLRW office is aware of the discrepancy between Cameco's position and the existing legal agreement. It says this will have to be resolved between the federal government, the municipalities and Cameco.

Some amendments will have to be made to the legal agreement because plans have changed since it was signed. For example, there will be only one site for the waste, not two (the Highland Drive site will be closed). This would give Cameco the chance to argue that future decommissioned waste from its site should be put into the Baulch Road storage facility. A future municipal council could come under pressure to reopen the LLRW facility to dispose of Cameco’s waste.

Suggested action: Natural Resources Canada is the signatory to the legal agreement for the federal government. We understand Cameco has had some conversations with the ministry about amending the agreement. As our member of Parliament, we request that you make Natural Resources Canada aware of the strong public concern in Port Hope on this issue, and press them for guarantees that the agreement will not be changed without a public referendum. In addition, the CNSC needs to require a substantial increase in Cameco's decommissioning guarantee, since it is based on using a disposal site that it has no legal access to.

Ongoing contaminants in soil

The federal government has committed $260 million to clean up historic wastes in Port Hope – an enormous burden on the taxpayers of Canada. At the same time, the current operations of Cameo and Zircatec result in uranium particulate emissions. In the case of Cameo, there has been extensive documentation over the years by the provincial Ministry of the Environment that the operations do add uranium to the soil each year. CASC is on record as agreeing with this finding, as recently as February 2005. The obvious question is who will pay for the next cleanup and the next one after that? Who will pay property owners for the loss of their property values and the content of the soil rises?

Suggested action: A strict policy of zero accumulation of radio-nuclides, chemicals and metals in the vegetation and soils of Port Hope must be applied to the polluting industries.

Back