CARN News….

Court Date Set For Judicial Review

On March 21, 2022, the Canadian Environmental Law Association (CELA) will be in Federal Court on behalf of Citizens Against Radioactive Neighbourhoods (CARN).  CARN, a Peterborough-based, grassroots organization, is asking the Federal Court to reconsider a decision by the Canadian Nuclear Safety Commission (CNSC).

The decision, which came on December 18, 2020, approved a 10-year licence to produce uranium fuel pellets at a facility located in downtown Peterborough, just metres from an elementary school and playground. CARN is seeking an order from the Court declaring that the CNSC’s issuance of the licence was unlawful, and for the licence conditions allowing for this change to be deemed invalid and of no effect.

In its decision, the CNSC identified serious deficiencies in the application. No detail was provided about what fuel pelleting would look like at the Peterborough facility, or how the surrounding community would be affected. Instead of applying the regulatory framework, the CNSC agreed to delay analysis of fuel pelleting until an undefined time, and in an undefined process. In CARN’s view, this decision severely undermines public trust in the CNSC’s process, and does not meet mandatory legislative and regulatory requirements. 

The CNSC’s original decision came after strong opposition from many local residents. In fact, the CNSC acknowledged that there had never been more community engagement in the history of CNSC hearings.

In a rarity for the CNSC, the Commission’s decision to expand BWXT’s license was not unanimous. Commission member Dr. Sandor Demeter, an associate professor in community health sciences at the University of Manitoba, dissented from the majority decision.

Dr. Demeter, an expert in clinical nuclear medicine, and the only Commission member with a medical degree, stated that adding radiation doses and uranium dioxide air and effluent emissions in a site which has an adjacent vulnerable population is not acting in an abundance of precaution.

Why Is This Judicial Review Important?

Apart from the obvious concerns that Peterborough residents have for a decision allowing an expanded class I nuclear facility in a residential area only 25 metres from a school, where a vulnerable population will be impacted by increased radiological emissions, all Canadians should be troubled by the approval of this expanded facility. At a time when nuclear reactors are aging and new untested and unproven technologies are considered by the CNSC to replace these aging reactors, it's more important now than ever before that the nuclear industry and Canada’s nuclear regulator play by the rules. This judicial review is being held because we believe that the decision to allow uranium dioxide pelleting in Peterborough does not abide by the rules as set out by the Canadian Nuclear Safety and Control Act.

Please help us by donating to our court fund.

City of Peterborough Recognizes CARN with a Community Betterment Award

Members of CARN were awarded the recognition as directed by resolution of the Council of the Corporation of the City of Peterborough. “Citizens Against Radioactive Neighbourhoods (CARN) worked very hard to inform, bring together and support residents in advocacy related to uranium pelleting concerns in the City. Thanks to the efforts of CARN volunteers, the Canadian Nuclear Safety Commission witnessed a great number of thoughtful and well-prepared oral presentations at the hearings.”

CARN is proud that its advocacy resulted in a record number of oral presentations for a CNSC hearing. CARN worked in conjunction with the Canadian Environmental Law Association ( CELA ) to help ensure that Peterborough residents’ advocacy was informed by fact.

CARN Undertakes Federal Court Action To Keep Our Community Safe

In December of 2020, the Canadian Nuclear Safety Commission (CNSC)  made a controversial decision to allow BWXT (a company with extensive links to the American arms industry) to expand its license to begin the manufacture of nuclear fuel pellets in a residential neighbourhood. 

The expansion of this license will increase the likelihood of exposure of children to radioactive particles. CARN believes that this decision sets a global precedent in allowing nuclear fuels to be manufactured only 25 metres from a public school.

The CNSC decision states “the transfer of the pelleting operations would increase the environmental emissions of UO2 in air and water and the resulting dose to the public in Peterborough.” However, in the decision only Dr. Sandor Demeter (also the only member of the CNSC with training in biology) cited international safety standards that limit the exposure of vulnerable populations to radiation. As noted in his dissenting opinion, “the potential inequitable increased exposure to the vulnerable population given the proximity of the Prince of Wales Public School” was a reason to refuse the  license expansion.

CARN agrees that an increase in radiation cannot be justified and seeks a federal court ruling that requires the CNSC to apply the precautionary principle and ALARA principle - basic safety principles that are embedded in Canada’s Nuclear Safety Act.  CARN is represented by the Canadian Environmental Law Association (CELA)

The CNSC must abide by the laws that govern it. A license expansion that adds radiation and uranium dioxide pollution to a site that has an adjacent vulnerable population does not comply with the Canadian Nuclear Safety Act or international norms. 

CARN undertakes this court action to ensure that our community is kept safe.

Did Peterborough Get A Fair Hearing?

When a nuclear safety regulator ignores international standards and licenses the manufacture of uranium dioxide fuel 25m from the junior playground of a school, it’s natural to ask if the license hearings were fair. Read more here.

Never Say No…..The Decision is Here

The CNSC released its decision on Dec 21st. Its decision favours the nuclear industry over vulnerable populations. Read more here.

Details About Hydrogen Explosion at BWXT’s Toronto Facility Revealed by CNSC

The CNSC discloses more information about two hydrogen events

Fun With Numbers

Read about the CNSC’s attempts to keep area residents from seeing trends in data here.

The Beryllium Problem; How the CNSC dealt with rising beryllium levels at a public school (In 7 easy steps)

Beryllium is a class I carcinogen and acknowledged to be one of the most dangerous industrial metals. Read more about how the CNSC dealt with concerns about the safety of children at a public school after their own data indicated kids may have been exposed to dangerously high levels of beryllium.

Step 1 Minimize Your Sample Size

In 2014, 2018 and 2019, the CNSC created a total of exactly 25 data points. Five years and 25 points! Productivity does not appear to be the CNSC’s strong suit.   By keeping the number of data points small, it makes it easier to claim that increases are not statistically significant. Which therefore raises the question - Why do the IEMP (Independent Environmental Monitoring Program) at all if your small sample size ensures statistical irrelevance? But maybe that’s why they kept the sample size small - so that the CNSC will never have a beryllium problem, statistically speaking.  

Step 2 Don’t Use A Control

We all learned in high school science that controls were necessary to allow for unbiased comparisons.  In this case, a control would have helped ensure that increases seen in soil beryllium were most likely to be caused by BWXT’s emissions. The CNSC introduced a control only in 2019 ;  5 years after they started their “Independent Environmental Monitoring Program”.  This control was located in Omemee and curiously, the beryllium levels in Omemee were almost the same between 2019-2020,  suggesting that the increases in soil beryllium were owed to something peculiar to Peterborough (like the BWXT plant)! Not using a control makes it more difficult to prove that there is a problem.  To quote CNSC staff “When we noticed there wasn’t a background sample being taken in 2018, we added it in 2019.” Nuclear safety shouldn’t be a learning experience! 

Step 3 Discredit Your Own Data

When the CNSC published IEMP data in 2014, 2018 and 2019, there was no discussion about error in the sampling. CNSC information touted “state of the art” laboratory facilities but did not discuss error in ANY of its reports. It was only after Dr. Julian Aherne did a statistical analysis on the CNSC data showing alarming increases in beryllium that the CNSC found error in its data - especially that from 2014. Up until Dr. Aherne’s intervention, the CNSC had “state of the art lab facilities” and a 0% reported margin of error. During the CNSC’s March hearings, CNSC staff “discovered” that the margin of error in their data was 40%. The October 2020 report inexplicably pushes this margin of error to plus or minus 80%. Many scientists find a margin of error of 40% as being unacceptably high and would not publish the data. While claiming that the high margin of error contributes to a lack of statistical proof for us to be concerned about rising beryllium levels, the high margin of error has not prevented CNSC staff from declaring the BWXT facility “safe”.

Step 4 Ignore the Expert 

During the March hearings, the CNSC promised to include Dr. Aherne in the IEMP program this summer “to improve the credibility” of the testing. Dr Aherne is the scientist who told the CNSC that beryllium was accumulating at an alarming rate which subsequently forced the the CNSC to conduct additional sampling this summer. The CNSC did not even have the courtesy to call Dr. Aherne before or after this summer’s IEMP sampling. Not including Dr. Aherne in the sampling and the subsequent analysis of data is inexcusable. The video accompanying this text comes from the March hearings in Peterborough. So much for “robust, solid and independent " monitoring!

Step 5 Obfuscate

CNSC officials and BWXT officials together with the Medical Officer of  Health have repeatedly stated that the level of beryllium in the soil is safe. No one has ever claimed  that the level of beryllium in the soil is unsafe!  It is the INCREASE in beryllium levels that is unsafe. CNSC staff know too well that the reason why they sample the soil is to watch for INCREASES in beryllium as a reflection of what’s happening in the air.   In Peterborough the increases in soil beryllium are large enough to warrant the concern of the MOECP, the CNSC, BWXT and the Medical Officer of Health.  

Step 6 Obfuscate Some More - Add Another Column to Your Data Table. 

Astute observers will note that there’s an extra column on the CNSC data table entitled “Partial Digestion”. This means that the lab procedure completed by the CNSC yielded only part of the total amount of beryllium in the soil. Being a different lab procedure, this data has NO RELEVANCE to the data collected in 2014, 2018 and 2019. This has not prevented the CNSC and BWXT from publishing the data and claiming that the soil beryllium levels are much lower. This is akin to saying “There’s less sugar in sugar free pop”, or driving your car without wearing your glasses and claiming there’s fewer pedestrians. If you extract only part of the beryllium in the soil, your results are going to show less beryllium in the soil!

Step 7 Drop the I in IEMP

One of the most alarming things that CNSC staff have done in their most recent report is to discredit their own data while adopting BWXT’s data as sacrosanct. In doing this, the CNSC removes the reason for conducting the IEMP in the first place - an “independent”  analysis of safety. In the CNSC’s own words the role of the IEMP is “to verify that the public and environment around CNSC-regulated nuclear facilities are not adversely affected by releases to the environment. This verification is achieved through independent sampling and analysis by the CNSC.” 

In their report, the CNSC claims that it is not possible for BWXT to be the source of beryllium because BWXT says it isn’t. According to John McQuarrie, president of BWXT Canada, “emissions from our facility in Peterborough are exceptionally low, about 15 milligrams into the air per year.” If Mr McQuarrie says BWXT releases 15 milligrams per year, then it has to be true. There’s no accounting for this ridiculously low figure and since BWXT reports its beryllium stack emissions to average zero on an annual basis, it’s a little hard to know where this number can come from. The CNSC goes on to say “This release is over 8000 times less than the mass of 133 g required to result in an increase of 1.07 mg/kg in soil over one year. Therefore, CNSC staff conclude that based on the calculation results, beryllium emissions from BWXT’s Peterborough operations are at a level that could not result in the change in beryllium soil concentrations.” 

What the CNSC doesn’t tell you is that 133g is not very much mass. It is about equivalent to the mass of 27 sheets of 8 x 11 paper. Raise your hand if you think it’s possible for BWXT to lose 27 sheets worth of beryllium through its stacks…. in a year!

The Boeing 737 Max provides us with an example of how short term profit in industry can override the safety of the public. It also points to the importance of a strong regulator ensuring the safety of the public. With the CNSC’s most recent report, the CNSC has failed to ensure that the neighbours of BWXT and children at Prince of Wales School are kept safe. 

Should our community expect better of the CNSC? 

It absolutely should! This facility is without international precedent in its proximity to a school and residential accommodation.  Instead of using state of the art technology, and the highest safety standards, the CNSC has conducted amateurish science and a form of statistical escapism to abrogate its responsibility to our community.

What do you think?

The CNSC says “it is unlikely there is any significant upward trend of total beryllium in soil concentrations since 2014.” Here’s the data in graphical form;

CNSC Hearing Transcripts Available

The CNSC has provided CELA with hearing transcripts by date. Please read the transcripts for veracity. We will link to video as soon as it becomes available.

• March 2, 2020

• March 3, 2020

• March 4, 2020

• March 5, 2020

• March 6, 2020

Peterborough Council Votes to Reject Pelleting

Led by Dean Pappas, city council voted to support the Medical Officer of Health before the CNSC. The Medical Officer of Health expressed her apprehensions about rising beryllium levels in the soil. The MOH seeks to confirm that airborne beryllium is not exceeding safe levels at Prince of Wales School and other locations near the plant before pelleting is approved at the site. The council voted to write a letter to the CNSC seeking rigorous beryllium testing

Uranium is “Relatively Dangerous”

The Medical Officer of Health calls uranium “relatively safe” when she should say that uranium is “relatively dangerous.” Members of CARN prefer to take a precautionary approach to the risks of uranium. Read more about our thoughts here.

Trent Academics Find Concerning Increase in Beryllium Levels.

In a letter published in the Peterborough Examiner, the Trent University science academics write “We are concerned because concentrations of the heavy metal beryllium (Be), which is used in the BWXT production process, have steadily and significantly increased in soil samples taken in the vicinity of BWXT since recording began in 2014. The clear increase of Be in soil samples is likely being driven by significant increases in air concentrations, which is particularly worrying because beryllium can be toxic if inhaled. More worryingly, the highest values of beryllium in 2019 were found in the samples in the Prince of Wales school playground. ” The full letter can be found here. An information sheet about beryllium can be found here. Beryllium is a Type I carcinogen. Please note, with the help of new Google imagery, the actual distance to the junior playground should be correctly measured as 50m. The beryllium soil sample data can be found on the CNSC’s website; https://nuclearsafety.gc.ca/eng/resources/maps-of-nuclear-facilities/iemp/bwxt-peterborough.cfm#sample_map

Questions Raised…..

What does this mean for kids and residents who have spent time around the BWXT plant?

Why did it take a group of Trent academics to raise the alarm?

How high were airborne beryllium levels to cause these increases?

Have airborne safety levels been exceeded?

Why did CNSC staff ignore its own data and recommend that BWXT be granted a license amendment to allow pelleting in Peterborough?

Why is there no mention of the changes in beryllium levels in the CNSC’s own report on the safety of this facility - a report that recommends that pelleting be allowed in Peterborough based upon the “safety of this facility. Unfortunately the CNSC’s own data indicates that this facility is NOT SAFE.

Why does the Independent Environmental Monitoring Program data seem to contradict BWXT’s own data on beryllium emissions?

CNSC - Isn’t the S for safety?

Interventions Record?

CARN is very proud to report that 249 interventions have been received by the CNSC for BWXT’s license application. This may be a record for the CNSC and we are ecstatic that so many of you have stepped forward. Peterborough Proud!!!

Is Uranium a Carcinogen?

“Because uranium decays by alpha particles, external exposure to uranium is not as dangerous as exposure to other radioactive elements because the skin will block the alpha particles. Ingestion of high concentrations of uranium, however, can cause severe health effects, such as cancer of the bone or liver. Inhaling large concentrations of uranium can cause lung cancer from the exposure to alpha particles. Uranium is also a toxic chemical, meaning that ingestion of uranium can cause kidney damage from its chemical properties much sooner than its radioactive properties would cause cancers of the bone or liver.” From the Centre For Disease Control

“Carcinogenic risks of internal exposures to alpha-emitters (except radon) are poorly understood. Since exposure to alpha particles—particularly through inhalation—occurs in a range of settings, understanding consequent risks is a public health priority.” “We found strong evidence for associations between low doses from alpha-emitters and lung cancer risk.” https://journals.lww.com/epidem/FullText/2017/09000/Risk_of_Lung_Cancer_Mortality_in_Nuclear_Workers.7.aspx

Class Action Lawsuit Against BWXT Over School Contamination

Zahn’s Corner Middle School in Ohio was suddenly closed on May 13, 2019 after uranium was detected within the school. The plaintiffs allege that BWXT “through their silence” and “aggressive public relations efforts,” misrepresented that their uranium enrichment operations did not contaminate the surrounding community. If you are wondering how a parent feels when their child has been exposed to uranium- read this article and watch the video. Think about it. Would you want anything above background for your child?

City Hall Wakes Up

On January 30th, Peterborough City Council finally woke to the potential risks of operating a class I nuclear facility in a residential area after Trent scientists raised the alarm about beryllium levels in soil. City hall has not questioned why it was a group of academics that raised alarm and not the CNSC, but has agreed to send a letter to the CNSC expressing concerns about beryllium levels. City Hall should have some very hard questions for the CNSC and its capabilities as a regulator. City Hall is also waiting for a report from the Medical Officer of Health before voting on a motion to oppose BWXT’s license amendment.

Sign The Petition

The petition is still live! We will bring a revised total to the CNSC hearings! Get your friends/neighbours/enemies to sign up!

City Hall Protest

On January 18th, About 80 concerned citizens braved blizzard conditions to tell Peterborough City Hall that putting a class I nuclear facility next to a school is NOT ACCEPTABLE.

Why An Intervention Is Important

Watch this short video based on CARN’s Intervention Workshop

New Section on Website

Read about CARN’s concerns about RISK IN OUR NEIGHBOURHOODS and how the CNSC doesn’t perceive risk in the same way was as other international regulators.