Lake Ontario Waterkeeper's submission Re: Ontario's Drinking Water Quality Standard for Tritium, EBR

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March 14, 2008

Mr. Scott Barrett Executive Assistant
Ministry of the Environment
Ontario Drinking Water Advisory Council 40 St. Clair Avenue West, 3rd Floor Toronto, ON M4V 1M2 Fax: (416) 212-7595


Re: Submission on Ontario's Drinking Water Quality Standard for Tritium, EBR Registry # 010-2757

Dear Mr. Barrett,

Please find enclosed Lake Ontario Waterkeeper's comments on the above-mentioned matter. We are scheduled to present to the Advisory Council on March 26, 2008 at 11:00 am. The attached commentary forms the basis for our oral presentation, as well as our written submission in response to the notice posted to the Environmental Registry on February 28, 2008.

If you have any questions or comments, please do not hesitate to contact me at any time: (416) 861-1237.

Yours truly,

Mark Mattson Waterkeeper & President

EXECUTIVE SUMMARY

Lake Ontario Waterkeeper is a Canadian charity working to win back the public's rights to safely swim, drink and fish in Lake Ontario. We have been involved in a number of energy and drinking-water related processes in the past, including environmental assessments and licencing hearings for atomic energy facilities in Ontario.

In this submission, Waterkeeper submits that the current drinking water standard for Tritium is not acceptable because it poses a threat to one of the province's most precious sources of drinking water - Lake Ontario. Waterkeeper submits that a more appropriate standard would be between 10 Bq/L and 20 Bq/L. 20 Bq/L.

BACKGROUND

Tritium is a form of radioactive hydrogen. It is produced naturally in the upper atmosphere and falls to the earth via rainfall. Natural background levels of Tritium in North American rainwater range from 0.05 Bq/L to 9 Bq/L. Levels of tritium above 9 Bq/L indicate Tritium from human-made sources is entering the environment. Such sources include nuclear weapons, nuclear reactors, and glow-in-the-dark sign manufacturers (Environmental Registry, document #010-2757). According to Greenpeace, as well as numerous other scientific sources, tritium is a carcinogen (i.e., causes cancer), a mutagen (i.e., causes genetic mutation), and a teratogen (i.e., causes malformations of the embryo) (2007, p. 8).

The Ministry of the Environment undertook a major review of Ontario's drinking water standards in 1993-1994. At that time, the Ontario Drinking Water Objective for Tritium was revised from 40,000 Bq/L to 7000 Bq/L (Ministry of Environment and Energy, 1993, Appendix E).

In 2006, the City of Toronto called upon the Ministry of the Environment to revise the Ontario Drinking Water objective for Tritium. The City referred to a 1994 report from the Advisory Committee on Environmental Standards, recommending an interim drinking water objective of 100 Bq/L. Further, the Committee recommended that feasibility studies be undertaken with the goal of lowering the objective to 20 Bq/L within five years, based on uncertainties in the risk assessment and the fact that Tritium is a carcinogen (ACES, 1994. p. ii).

Greenpeace also called upon the government to act in 2007, citing high Tritium discharges from Canadian nuclear power stations, high levels of Tritium in the Great Lakes, increasing levels of Tritium in air, water, vegetation and food near CANDU stations, and risks to pregnant women and children under four years old living within ten kilometres of Tritium-emitting facilities (2007. p. 5).

On February 21, 2007, the Ministry of the Environment requested that the Ontario Drinking Water Advisory Council (“ODWAC") review and provide advice to the Ministry regarding Ontario's drinking water standard for Tritium (ODWAC Backgrounder, p. 1). Lake Ontario Waterkeeper offers this commentary as part of the ODWAC's consultation process.

COMMENTARY

In its guidance documents, the ODWAC asks if the current Ontario Drinking Water Quality Standard for tritium is acceptable? If not, why not? And, what different standard is recommended and why? Waterkeeper submits that the current standard is not acceptable because it poses a threat to one of the province's most precious sources of drinking water - Lake Ontario. Waterkeeper submits that a more appropriate standard would be between 10 Bq/L and 20 Bq/L.

The current drinking water standard for Tritium is unreasonably lax

The current drinking water standard for Tritium is less protective than most jurisdictions. Of seventeen non-Canadian jurisdictions examined by the Canadian Nuclear Safety Commission, thirteen have more protective standards than Ontario's. Of the four jurisdictions with standards more lax than Ontario's standard, one is deemed non-compliant with an EU Council Directive (Finland), and one relies on a “tolerance level†of 1000 Bq/L - much lower than the standard at which water is no longer deemed fit for drinking (Switzerland). Thus, of all the countries with established drinking water objectives for Tritium, only Russia and Australia are in practice less protective than Ontario (CNSC, 2008, p. A2-A54). There is little reason to assume that Ontario residents deserve less protection than residents in other jurisdictions.

The current drinking water standard for Tritium is less protective than the standard recommended by the Advisory Committee on Environmental Standards. In 1994, the Advisory Committee recommended an Ontario drinking water objective for Tritium of 100 Bq/L. This objective was considered feasible at the time, and believed to be increasingly feasible as background levels declined in the response to decreases in weapons testing. The Committee also recommended that feasibility studies be undertaken with the goal of lowering the objective to 20 Bq/L within five years. This lower objective was based on uncertainties in the risk assessment and the fact that Tritium is a carcinogen (ACES, 1994. p. ii).

The current drinking water standard for Tritium is failing to protect the Great Lakes. Lake Ontario is a source of drinking water for more than seven million people. Any threat to this water supply threatens the environmental, social and economic health of the entire province. Greenpeace documents in great detail the way in which Tritium is contaminating our lakes, air, vegetation, and food supply (2007). The Canadian Nuclear Safety Commission reports that Tritium concentrations near nuclear sites in Ontario are as high as 114.7 Bq/L (CNSC, 2008, p. 11-12). The Ministry of the Environment similarly identified Tritium concentrations in Lake Ontario at 130 Bq/L (MOE, 1993, Appendix D). Of particular concern is Greenpeace's conclusion that Tritium levels in Lake Ontario are increasing (2007, p. 36) and the clear link between nuclear power plants and Tritium contamination in the environment. Standards should be set which first and foremost protect the health and safety of people and our natural environment.

The drinking water standard for Tritium should be between 10 and 20 Bq/L

Water treatment systems are not able to remove Tritium from our water (Ministry of the Environment, 1993, p. 23). Thus, even if we disregard the threat to the natural environment, we cannot assume that drinking water treatment systems will protect our public water supply.

Given that Tritium can result in cancer, genetic mutation, and harm to embryos, it is reasonable to expect that no one wants more Tritium in the Great Lakes ecosystem. Furthermore, it is reasonable to expect that the Ministry of the Environment would take steps to protect human and aquatic life and to hold polluters accountable.

The EU and the Advisory Committee on Environmental Standards recommend a drinking water objective for Tritium of 100 Bq/L. Waterkeeper notes that the Advisory Committee also recommended a longer-term goal of 20 Bq/L and submits that this standard is more appropriate for Ontario. The Great Lakes form one of the most precious ecosystems on the planet. Their freshwater sustains millions of people. A regulatory system that permits some Tritium pollution sends entirely the wrong message to the operators of nuclear facilities; it suggests that some leaks are acceptable, that some mistakes may happen. Waterkeeper submits that clean water is too important to our community. Thus, we recommend an objective for Tritium in drinking water that is as close to background as possible.

REQUEST

In light of the above commentary, Lake Ontario Waterkeeper recommends that the Ontario Drinking Water standard for Tritium be revised to between 10 Bq/L and 20 Bq/L.

REFERENCES

Advisory Committee on Environmental Standards, 1994. A Standard for Tritium.

Canadian Nuclear Safety Commission, 2008. Standards and Guidelines for Tritium in Drinking Water.

Environmental Registry Document #010-2757. “An invitation by the Advisory Council on Drinking Water Quality and Testing Standards to participate in a public consultation meeting on Ontario's Drinking Water Quality Standard for Tritium.†Retrieved online March 14, 2008 at http://www.ebr.gov.on.ca/ERS-WEB-External/ displaynoticecontent.do?noticeId=MTAyNzM4&statusId=MTUzNTQ2&language=en

Greenpeace Canada, 2007. Tritium Hazard Report: Pollution and Radiation Risk from Canadian Nuclear Facilities.

Ministry of Environment and Energy, 1993. Rationale Document for an Interim Tritium Standard.

Ontario Drinking Water Advisory Council. n.d. Backgrounder. Retrieved online March 14, 2008 at http://www.odwac.gov.on.ca/standards_review/tritium/ ODWAC_Tritium_Consultation_Backgrounder.pdf