Radiation Protection Regulations and Disproportionate Impact Exposure

 #88774  re DGR Impact Project Description

"It's safe, it's safe, it's safe."  The Nuclear Waste Management Organization (NWMO) has been spouting for over two decades.  The problem is that they never give details on how they plan to ake the project, from beginning to end, safe.

OMISSIONS REGARDING SAFETY

The NWMO begins their Description of Project in the IPD (vii): "The project will include: 1) underground repository; 2) surface facilities for receiving, handling, and packaging the used fuel; 3) transportation along roads within the site; and 4) supporting infrastructures.  It does not mention the promise of safety for humans and environment, or even a concern for thir health and well-being.  In other publications, the same holds true.  The issue of safety for people is found mentioned in a couple of paragraphs at the very end of a booklet, althoug the first sentence in the publication will be something such as "the fundamental (or primary) safety objective of the project is to protect humans and the environment, including water." ("Confidence in Safety - Revell Site NWMO " TR-2022-Mar 2022.)  In reality, the NWMO has been remiss in not informing people in detail about the risks and dangers of the project since the beginning of their promotional Site Selection stage.

I am a person living about 40 km from the 'chosen' Revell Lake site.  I am very concerned about the proposal of having a nuclear waste dump anywhere but at the original production plants.  Ionizing radioactive waste from nuclear reactors  (high-level nuclear fuel waste) is the most dangerous of all substances known to mankind.  During the reacctor process to ake electricity, over 200 radioactive elements and materials, most of which are not found in nature, are never-before known and highly radioactive man made.  This is the reason why, globally, there have been no successful operating Deep Geological Repositories or other proposed means of storing the waste away from the sites.  It is simply too difficult to contain the waste from people and environment - radioactive, invisible, cannot be felt or tasted, or heard.  So there is no way for a person to know when they are within distance of harm from gamma rays (externally penetrating), alpha or beta particles (ingested internally from air, food, or water.)  How these radioactive long-lived  materials wll react inside the DGR over the first 20 years, 50 years, never mind the millennia existence of some of them nobody knows.  (NWMO may surmise, without any way to prove.)

From various scientific research studies, findings report that current Radiation Protection (RP) Regulations are vastly insufficient in keeping safe occupational workers and the public.  The current radiation risk model is from the International Committeeon Radiation Risk (ICRR) based in the USA, and the International Atomic Environmental Agency (IAEA)Safety Standards.   However, in 2007, the National Academy of Sciences (NAS) published the "Biological Effects of Ionizing Radiation" (BEIR VII, 2007), reporting that these standards set as normal globally, are in no way safe, and that bodies exposed to even very low doses of radiation can cause cancer.  Several other studies have found similar results.

The latest INWORKS Study - nuclear worker cancer studies, show that the Absorbed Dose No-Nuclear-Threshold (LNT) theory, of which the NWMO and CNSC intend to follow its guidelines, to be wrong.  The study finds thatnuclear workers are a high risks at low dose exposures.

Background radiation, that found in nature and to which we are all exposed, is generally averaged to be about 1.8 (NWMO), but could be much higher (e.g. Winnipeg at 4.0 in 2020).  This amount plus any exposure from medical procedures using radiation medicine, andin many other industries, add to the accumulation of exposure in our bodies.  So any additional radiation can be too much, and would add to the  risk of developig cancer or heart disease or a number of other health-related problems, including neurological.

The Canadian Nuclear Safety Commission (CNSC) has set standard dose limits for our populations in "Effective Dose Limits," in units of mSv. 1000 mSv equals 1 Sievert.  A nuclear worker, or occupational employee's dose limit considered as "safe exposure", is 20 mSv per annum (no more than 50 mSv in one year with total of 100 mSv in 5 years), in comparison to the public limit at 1 mSv a year.  For a pregnant nuclear worker, the dose exposure limit is 4 mSv, but only if that woman has registered herself as pregnant.  Otherwise, she is allowed the same as male worker, at 20 mSv per annum.  These are 'normal' requirements, not the same as when an emergency should arise, which would then be increased exponentially.

The nuclear industry attempts to go by the "As Low as Reasonably Achievable."  This really means as low as long as it allows the iondustry to operate - not as low as will prevent safety for workers, their families, the public and generations to follow.

In 2006, an article "Science for the Vulnerable" was released from the Institute for Energy and Environmental Research (IEER) on the "Analysis of Cancer Risks for Populations near Nuclear Facilities, Phase 1"  IEER .org  It advises more investigation for the following concerns:

- adverse health outcomes should be evaluated;

- cancer incidence for various cancers, including leukemias, brain and nervous system cancers;

- cancer deaths;

- early failed pregnancies;

- malformations as affected by early embryo/fetus exposure (in the first 14 weeks);

- immune system function as affeccted by fetal exposure at the time of bone and bone marrow formation

Page ix of the IPD Description of the project, #4: Assessments of radiation risks from the project:

"the likelihood of significant adverse environmental effects is expected to be low."  I do not agree with this statement, with regards to the whole immense project, and the many opportunities for emission to escape.  Historically, the record of nuclear energy in Canada and abroad has revealed a myriad of problems with contamination on and near nuclear facility sites and downstream communities from the sites, numbers of people whose health and environments have beenaffected in ways that have not been able to be made safe; the effects still being felt globally from the nuclear bombings, nuclear testings, and nuclear accidents.  It is untrue that there have been no transport accidents of nuclear loads.  There was one not far from Dryden, for instance.  The NWMO was eventually willing to admit that, at one of their 'information' meetings.

I refer to Comments on the IA Registry, Project DGR #88774, No. 412, "Scientific Evidence for the failure of the current exposure limits," Author European Committee on Radiation Risks (ECRR).  Excellent Report.