FAQ – BWXT

We encourage you to send us your health-related questions about upcoming re-licensing of BWXT in Peterborough. All questions will be reviewed and those within the scope of Peterborough Public Health will be answered by a Public Health Inspector and posted below. If your question is not health-related, we will provide a referral for the agency that is better-suited to answer the question. Your question will remain anonymous except for your street name and municipality.

Here are some frequently asked questions updated as of 3:52 PM February 28, 2020

1. What are the health risks to local residents and students/staff of Prince of Wales School if BWXT starts producing uranium pellets?

Prepared by Peterborough Public Health

A. If pelleting operations are relocated to Peterborough, the emission of uranium would be expected to increase to similar amounts observed at the Toronto facility. A review of the data from the Toronto facility over the last five years shows that uranium emissions in the air have ranged from 6.3 to 10.9 grams per year. Although this is many times higher than the current air emissions of uranium at the Peterborough facility, it is still well below the licence release limits which ensure the radiation dose to the public remains below 1 milliSievert (mSv).

Additional air monitoring is conducted at the boundary of the Toronto facility and over the last three years, the highest average concentration was thirty times lower than Ontario’s Ambient Air Quality Criteria (AAQC) limit. As long as uranium emissions remain below the AAQC limit, there is no health risk to local residents and students/staff at Prince of Wales School.

2. What are the health risks to employees of BWXT if starts producing uranium pellets?

Prepared by Peterborough Public Health

A. Data provided by the Canadian Nuclear Safety Commission (CNSC) and BWXT has been reviewed to determine whether or not emissions are posing a risk to the health to the general public. Peterborough Public Health does not have data on occupational health as this falls within the mandate of Ontario’s Ministry of Labour and are outside the scope of this review.

3. Isn’t there a risk that the BWXT facility might produce fugitive dust?

Prepared by Peterborough Public Health

A. Release limits are established according Canadian Standards Association Guidelines[i] and are considered key to the protection of human health and the ambient environment.[ii]  A review of the 2011- 2018 data from the Toronto facility show that uranium emissions in the air have ranged from 6.3 to 10.9 grams per year. Although this is many times higher than the current air emissions of uranium at the Peterborough facility, it is still well below the licence release limits.

PPH Staff toured the BWXT Toronto Facility on February 11, 2020. The uranium dioxide product arrives to the facility in plastic-lined drums. When the drum is opened for processing, it is taken into a negative-pressure room. The lid of the drum is removed under a fume hood and the liner is adjusted to ensure that all uranium dioxide is settled into the drum. There is no visible dust produced as a result of this procedure. It should be noted that uranium is heavy so it has a tendency to settle versus become airborne. (While a gallon of milk weighs about 8 pounds, a gallon container of uranium would weigh about 150 pounds.) Once the drum is open and the liner adjusted, a heavy metal cone is attached to create a seal over each drum and then the drum is inverted to add the product to the manufacturing line.

The uranium dioxide is then compressed into coarse pellets, which happens in a hood.  Once in its pellet form it is then baked (sintered) in the hydrogen-fired oven, then ground down to precise measurements using water in the process. The pellets are placed in trays, inspected and packaged for shipping. No fugitive dust was observed during the tour.

[i] CSA N288.1 (2014) Guidelines for Calculating Derived Release Limits for Radioactive Material in Airborne and Liquid Effluents for Normal Operation of Nuclear Facilities
[ii] Process for Establishing Release Limits and Action Levels at Nuclear Facilities. Canadian Nuclear Safety Commission. https://nuclearsafety.gc.ca/eng/pdfs/Discussion-Papers/12-02/February-22-2012-DIS-12-02-Process-for-Establishing-Release-Limits-and-Action-Levels-at-Nuclear-Facilities_e.pdf

4. What is PPH doing to protect the public from uranium exposure?

Prepared by Peterborough Public Health

A. PPH has completed a comprehensive review of the Commission Member Document and BWXT compliance reports to identify and assess potential health hazards from the operations at BWXT.   PPH has consulted with experts at Public Health Ontario and the Ministry of the Environment, Conservation and Parks to review regulatory limits and evidence surrounding health-related impacts. PPH has also engaged an expert in environmental monitoring to propose a comprehensive monitoring program that would ensure that sufficient data is collected to assess the full extent of uranium emissions into the environment.

On January 27, 2020, PPH submitted a written intervention to the CNSC with a request to present orally during the public hearings in Peterborough. PPH is urging commission members to consider the following additional recommendations before approving the licence renewal:

1. That BWXT implement a comprehensive environmental monitoring program to provide sufficient data to assess the full extent of uranium and beryllium emissions in the surrounding area prior to any decision regarding renewal of the licence and the addition of pelleting at the Peterborough site.
2. That the BWXT Peterborough facility retain the services of an independent, neutral third party for soil, water, and air testing for Uranium and Beryllium, as appropriate, and publicly share all reports and test results in their entirety; and
3. That the BWXT Peterborough facility establish a Community Liaison Committee (CLC) in Peterborough, similar to that which has been established in Toronto.

On February 11, 2020 PPH staff, management and executive toured the BWXT Toronto facility in order to better-understand pelleting operations and the potential risks in the event that pelleting operations are relocated to Peterborough. The objectives of the tour were to:

• • Be able to visualize the pelleting process
  • To learn about the depth of safety measures that exist in the Toronto plant
  • To understand the uranium monitoring process
  • To understand the role of hydrogen in the process and learn about the safety measures in place

5. What happens if there is an emergency spill or explosion at the BWXT facility? How will people be protected?

Prepared by Peterborough Public Health

A. According to the BWXT 2018 Annual Compliance and Monitoring Report, there are fire safety and evacuation emergency response plans at the Peterborough facility. PPH staff consulted with City of Peterborough staff, who indicated that fire services and emergency management staff meet annually with BWXT to discuss emergency response and review emergency response plans. City staff advised that in the event pelleting is relocated to Peterborough and there is the need to store liquid hydrogen at the facility, protective measures will be required and implemented.

6. How will public health risks be monitored if uranium pelleting production is allowed at BWXT?

Prepared by Peterborough Public Health

A. Peterborough Public Health has requested that the CNSC ensure:

1. That BWXT implement a comprehensive environmental monitoring program to provide sufficient data to assess the full extent of uranium and beryllium emissions in the surrounding area prior to any decision regarding renewal of the licence and the addition of pelleting at the Peterborough site.
2. That the BWXT Peterborough facility retain the services of an independent, neutral third party for soil, water, and air testing for Uranium and Beryllium, as appropriate, and publicly share all reports and test results in their entirety.

Also, the CNSC has recommended the following release limits:

Proposed Release Limits (2021-2030)

1. The licensee’s environmental protection program shall ensure control, monitoring and recording of environmental emissions from the Peterborough facility such that the releases do no exceed operating limits defined below:

Proposed Peterborough Environmental Emissions Action Levels

Action levels are set limits that are lower than the facility’s release limits. They ensure that release limits are not exceeded by providing an early warning system of a potential loss of control of the Environmental Protection Program.[i]The licensee’s environmental protection program shall have action levels for environmental emissions. The environmental emissions action levels for the Peterborough facility are:

[i] A Licence Renewal BWXT Nuclear Energy Canada Inc.:  Application to renew licence for the Toronto and Peterborough Facilities. Canadian Nuclear Safety Commission. http://www.nuclearsafety.gc.ca/eng/the-commission/hearings/cmd/pdf/CMD18/CMD20-H2.pdf

7. What is PPH’s role in relation to the Canadian Nuclear Safety Commission to ensure public safety?

Prepared by Peterborough Public Health

A. Peterborough Public Health is mandated by the Ministry of Health to conduct surveillance of environmental factors and identify health hazards in the community.  As part of this work, PPH will collaborate with relevant regulatory authorities like the CNSC and the Ministry of Environment, Conservation and Parks. PPH will be present and available for questions at the hearings in March and has also submitted recommendations to the CNSC for an enhanced environmental monitoring program.

PPH staff periodically meets with representatives from BWXT and reviews monitoring data.

8. What will be done to contain the air in the facility so that fugitive unaccounted for emissions don’t further contaminate the environment?

Submitted by Paterson St., Peterborough

A. For questions that pertain to the natural environment please contact the Ministry of Environment, Conservation and Parks.  Also, the Commission Member Document provides detailed plans for environmental protection.

9. If pelleting begins, by what factor will the risk of getting cancer increase in Peterborough and by what factor will our exposure to heavy metals increase?

Submitted by Paterson St., Peterborough

A: It is anticipated that if pelleting is added to the operations at the Peterborough plant that exposures will be similar to the Toronto plant.  Natural uranium is radioactive but only weakly so, and its radiotoxicity is quite low. However, as a heavy metal it is a chemical hazard, similar to lead. Its chemical toxicity is of much greater concern than its radiotoxicity. There is no evidence that there will be an increased risk for cancer.  The International Agency for Research on Cancer has not classified uranium as carcinogenic.

10. Do the people of Peterborough understand that similar to the cancer-causing potential of one single asbestos fibre, breathing in just one particle of uranium is extremely dangerous?

Submitted by Paterson St., Peterborough

A:  Exposure to ‘one particle’ does not make any difference to overall cancer risk from ionizing radiation, as everyone is already exposed to far more than ‘one particle’. Even though uranium is considered to be only weakly radioactive and not carcinogenic, it is still a toxic substance. With all toxic substances, rather than the ‘one particle’ we are concerned more about the overall exposure that will come from the plant and whether this will make any difference to the health of people in the community. Independent air sampling in multiple sites carried out in 2019 did not find any detectable levels of uranium present in the ambient air.

11. How can the CNSC approve or deny a license for a new industrial process without an independent scientific review of the risks to the surrounding air, land, water, wildlife and people?

Submitted by Paterson St., Peterborough

A. Please direct this question to the CNSC.

12. Dr. Salvaterra, in your opinion does the track record of the CNSC show that it puts Canadians or the nuclear industry first?

Submitted by Paterson St., Peterborough

A: Canada’s Nuclear Safety and Control Act, passed in 1997 establishes the CNSC to do the following two tasks:

1. Oversee the development and functioning of sectors that use radioactive substances in order to protect the environment and populations, prevent any risk to national security, and conform with international obligations; and
2. Public education on the scientific, regulatory and technical aspects of all this work.

The CNSC does not have a role in promoting the nuclear industry. Peterborough Public Health has been engaged with the CNSC on two matters: emergency preparedness in response to a nuclear incident at the Pickering and Darlington facilities, and the licensing of BWXT in Peterborough as a Class 1 Nuclear Facility. In both instances, we have found their staff to be knowledgeable, responsible and thorough. We have no reason to doubt their commitment to regulate the industry, as mandated through legislation, in a way that ensures the safety of communities like Peterborough.

13. The BWXT-Peterborough facility sits on the traditional territory of the Anishinaabeg Mississauga. Has BWXT received their permission for this new industrial process?

Submitted by Paterson St., Peterborough

A:  Please direct this question to the CNSC

14. If pelleting begins, will the city of Peterborough, the federal government of BWXT accept some of the responsibility of the consequences of pelleting before and after Peterborough? Will some of the profits of the tax revenue go towards compensating the uranium miners in Northern Saskatchewan/Dene Territory who get lung cancer? Will the highly radioactive consumed fuel rods, return to Peterborough and be safely stored for the next 200,000 years?

Submitted by Paterson St., Peterborough

A: Please direct this question to your political representatives and BWXT.

15. If pelleting begins, 1,500 metric tons of uranium powder and a 9000-gallon tank of liquid hydrogen will be on-site. What is the worst-case possible accident?

Submitted by Paterson St., Peterborough

A: BWXT has not requested any changes to its existing uranium possession and production limits. It currently can possess up to 1,500 tonnes of uranium at its Peterborough site. Pelleting will require the addition of liquid hydrogen.

BWXT maintains an acceptable Fire Hazard Analysis for operations in Toronto and Peterborough.  As per the Commission Member Document, BWXT’s Emergency and Fire Protection plans are reviewed every year and updated as needed. They are verified through regular testing, scheduled emergency drills and exercises as defined in the plans, and are supported by event specific procedures, standard operating guidelines, and pre-incident plans. BWXT also maintains required arrangements with offsite response organizations (fire, security and emergency medical services) to provide support for emergencies at each of the facilities. BWXT conducts regular exercises involving offsite response organizations to ensure their familiarity with the site, opportunities to train together, as well as to ensure integration of BWXT staff with off-site response organizations for direct facility-related support.

Since this is not a health-related question further queries regarding accidents would be better directed to a local or provincial Risk Assessment Officer.

16. Dr. Salvaterra, in your personal opinion, if pelleting begins, is the proximity of the facility to public schools acceptable?

Submitted by Paterson St., Peterborough

A: The proximity to a public school is not ideal.  That is why a rigorous environmental monitoring and surveillance program should be implemented. PPH is also recommending a stronger engagement of community representatives, similar to the model used in Toronto, as an ongoing way to address concerns and review data in a timely and effective manner.

17. If pelleting begins and my property value goes down, will I receive compensation from the federal government?

Submitted by Paterson St., Peterborough

A: Please direct this question to your realtor or political representative.\

18. The Examiner quotes the Medical Officer of Health as noting that uranium is “relatively safe.” Are the safety levels measured on adults or children?

Submitted by King St., Peterborough

A: In Dr. Salvaterra’s full statement, she was comparing the risk of uranium to the risk from another alpha-emitting radionuclides, Radon 222. The evaluation of all hazards typically includes data from lab testing, animal tests, studies of workers, and studies of human health. Sometimes children have been included in these studies, and sometimes, not. Working with all of the evidence available, toxicologists calculate a safe human dose, based on the scenario of a lifetime of exposure. In addition to using this scenario of maximum exposure, additional allowance is made to account for the differing susceptibilities in humans, like children or the infirm. If data is not available, an “Uncertainty Factor” is incorporated into the calculation of a safe human dose.

There are many types of nuclear installations around the world including those which manufacture and use enriched uranium which is much more likely to have an impact on health than the natural uranium used in manufacturing processes in Peterborough.  PPH has reviewed the evidence related to health impacts of the proposed operations and believes the current regulations to be health protective for our community.

19. 1 The Medical Officer of Health is quoted as saying “there is not an impact on human health at the BWXT facility.” What is the impact of beryllium on children?

Submitted by King St., Peterborough

 (Full Question) The Medical Officer of Health is quoted as saying “there is not an impact on human health at the BWXT facility.” Given that the International Atomic Energy Association guidelines state that schools need special attention (“6.8. Information on the existing and projected population distribution in the region, including resident populations and (to the extent possible) transient populations, shall be collected and kept up to date over the lifetime of the nuclear installation. Special attention shall be paid to vulnerable populations and residential institutions (e.g. schools, hospitals, nursing homes and prisons) when evaluating the potential impact of radioactive releases and considering the feasibility of implementing protective actions.” What is the impact of beryllium on children?

A: Human exposures to beryllium are primarily in the workplace and the respiratory tract is the prime target. Human and animal data provide evidence that inhaled beryllium is a human lung carcinogen. It also causes inflammation. There is very limited data for beryllium in children: children have been exposed to beryllium dust on the clothing of parents, the most recent case in the literature being in 1992, as well as from beryllium in the soil. There are animal studies that show inconsistent results in the developing fetus of dogs and rats. Toxicological profiles for beryllium have identified this as an area that would benefit from more research.

20. What are your sources for all of the conclusions you make about uranium etc. and safety?

Submitted by King St., Peterborough

A: United Nations and World Health Organizations such as UNSCEAR (The United Nations Scientific Committee on the Effects of Atomic Radiation), The International Agency on Research in Cancer (IARC), the Agency for Toxic Substances and Disease Registry (ATSDR) which is a federal public health agency within the United States Department of Health and Human Services; and CAREX Canada, funded by the Canadian Partnership Against Cancer and hosted at Simon Fraser University are sources that were accessed for our assessment.

21. The Examiner quotes the Medical Officer of Health as noting that uranium is “relatively safe” (do we release murderers from prison if they are deemed “relatively safe”?). What exactly does this mean? If it is relatively safe, how is it relatively unsafe?

Submitted by King St., Peterborough

A: In the case of natural uranium, composed mostly of U238, the use of the words “relatively safe” are in reference to other sources of radiation, and especially, other alpha-particle emitters, such as radon gas. Please see the answer to question 18 above.

22. An alarming increase in Beryllium levels–from the CNSC website–in soil samples at Prince of Wales school contradicts the information released by BWXT. What is your take on this?

Submitted by King St., Peterborough

A: Soil monitoring in Peterborough is not required as part of BWXT’s operating licence, however, it too is conducted as part of CNSC’s Independent Environmental Monitoring Program. The upper limit has been steadily increasing: 1.1 mg/kg (2014) 1.34mg/kg (2018) and 2.34 mg/kg (2019). Although the results continue to be below the Canadian Council of Ministers of the Environment Soil Quality Guidelines (4.0 mg/kg), the results are approaching the guideline and require further study to determine their source. Increasing concentrations are a potential concern, given the proximity of the facility to the elementary school across Monaghan Road, for which the playground for the youngest and potentially the most vulnerable children is directly across from the facility. Although there is little evidence indicating children are more susceptible to the toxic effects of beryllium, they may be at risk of increased exposure through ingestion and dermal contact. Contrary to how the question has been framed, these results do not “contradict” information released by the CNSC. They actually supplement results done in previous years and support the observations of an upward trend.

23. Everyone agrees there is a risk. Calculating risk is not just about what the likelihood of an accident is. It’s about how catastrophic an accident might be. The Hippocratic Oath is “Do No Harm”– why is any risk worthwhile? How does accepting risk fit with the Hippocratic Oath?

Submitted by King St., Peterborough

A: In setting limits for daily exposures, or in deciding to licence a Class 1 Nuclear Facility or not, the health and safety of both workers and the general public are seen as a priority consideration. In the licensing of Class 1 Nuclear Facilities in Canada, legislation mandates that both the normal operation of the facility, as well as accidental or emergency situation be addressed. BWXT is not a nuclear reactor site. There is no nuclear fission taking place, hence there are no highly radioactive emissions or waste either present or possible. The worst-case scenario is a fire, and the CNSC has strict requirements and checks to ensure BWXT addresses this risk including the requirement for a emergency response plan that is exercised in collaboration with the City of Peterborough’s fire department.

24. How is beryllium tested?

Submitted  by KPR District School Board

A. Currently, BWXT is doing continuous in-stack monitoring for beryllium concentration in the emissions coming from the plant. It involves drawing air through a filter capable of trapping beryllium. Waste water leaving the plant is also tested for beryllium prior to its release to the sanitary sewer. Additional air and soil samples were collected and tested by the Canadian Nuclear Safety Commission (CNSC) as part of the Independent Environmental Monitoring Program (IEMP). In order to understand the beryllium soil testing procedure, we would encourage you to contact the CNSC at Canadian Nuclear Safety Commission.information.ccsn@canada.caor call 1-800-668-5284. Additionally, more information may be available on the IEMP webpage at: https://nuclearsafety.gc.ca/eng/resources/maps-of-nuclear-facilities/iemp/bwxt-peterborough.cfm.

25. In the case of Prince of Wales, is beryllium found at the surface level or significantly below the surface? If so, at what depth? Are there any concerns with our students playing in the soil, rolling on the ground in the spring and summer, etc.?

Submitted by KPR District School Board

A. Details related to the sampling methodology can be provided by the Canadian Nuclear Safety Commission at the contact information mentioned in question number one. The sample results indicate that the levels of beryllium in the soil are within the regulated limits, according to the Canadian Council of Ministers of the Environment (CCME) Canadian Soil Quality Guidelines for the Protection of Environmental and Human Health. Accordingly, the risk to students is very low.

26. How many soil samples were taken and tested from Prince of Wales? Where specifically were the soil samples taken on the Prince of Wales site? Do they represent the whole site or just the south end of the school across from BWXT? Does the current reading of 2.34 represent the whole site?

Submitted  by KPR District School Board

A. Details about the sample locations can be found on the Canadian Nuclear Safety Commission’s Independent Environmental Monitoring Program (IEMP) webpage at: https://nuclearsafety.gc.ca/eng/resources/maps-of-nuclear-facilities/iemp/bwxt-peterborough.cfm#background. There are specific site codes for each soil sample site. Details regarding the locations of specific samples can be provided by the Canadian Nuclear Safety Commission.

27. Should there be discussion about how to treat it and/or get rid of it? In other words, are the rising levels inevitable? Is there a way to stop the increase?

Submitted  by KPR District School Board

A. At this stage, Peterborough Public Health is recommending that additional sampling be conducted around the grounds of the Prince of Wales school in order to determine if the increase is a result of natural environmental variation or if there is an association with emissions from BWXT. Determining the need for remediation cannot be completed until a robust sampling program is implemented. However, at this stage, it is important to note that levels of beryllium in the soil are within the range considered to be safe. It is important to note that although the Canadian Soil Quality Guidelines have used a maximum concentration of 4 mg/kg for beryllium for Residential/Parkland land use since 1991, a 2015 review found that 75 mg/kg would be protective of human health. The concentrations found in the soil samples are well below this level.

28. How does beryllium impact humans given your reference to possibly impacting the respiratory system (lung cancer) and dermal (skin contact)?

Submitted  by KPR District School Board

A. Most information regarding adverse health effects in humans after the inhalation of beryllium come from occupational exposure studies, where significant exposure has occurred. The respiratory tract is the primary target of beryllium toxicity. Inhalation of beryllium dust or fumes in an occupational setting can result in acute or chronic beryllium disease, which is scarring of the lungs that is irreversible and potentially fatal. Lung cancer may also be a result of occupational beryllium exposure. It is important to be mindful that the health-related outcomes described above are observed only in occupational settings. Beryllium is not likely to cause any respiratory disease from exposure in the general environment because ambient air levels of beryllium are very low.
Dermal exposure to beryllium compounds can cause both irritation and inflammation, with the possibility of sensitization and risk for chronic beryllium disease. In a study of residents living close to a beryllium manufacturing facility where airborne concentrations were up to 100 times greater than the current guidelines allow, there were NO cases of chronic beryllium disease (Eisenbud et al, 1949).Hence, we do not expect to see any skin or sensitization associated with the levels currently present in Peterborough air or soil.

There is very limited data for beryllium in children: children have been exposed to beryllium dust on the clothing of parents, with only one case reported in the literature being in 1992, as well as from beryllium in the soil. There are animal studies that show inconsistent results in the developing fetus of dogs and rats. Toxicological profiles for beryllium have identified this as an area that would benefit from more research.

29. Do we have any idea whether this increase is due to activities by BWXT or previous operators of the GE site?

Submitted  by KPR District School Board

A. At this point, the precise cause of the increase of beryllium concentrations in the soil samples is unknown. It is entirely possible that the increase may be the result of natural variation in the soil and/or an artefact of field sampling. Again, it is important to recognize that the levels of beryllium detected in the soil are within regulated limits and well below the levels deemed to be protective for human health. However, it is also possible that the increase may be a result of emissions from the BWXT facility. We are not aware of any data from soil samples collected prior to 2014. Working with the data available from 2014 to 2019, we have concluded that more sampling is required in order to confirm whether there truly is an increase of beryllium in the soil and to determine the cause of the increase.

30. Given the Medical Officer of Health’s concerns with rising beryllium levels in the soil, is mandatory soil testing now required? Whose responsibility is it to ensure testing occurs and what is the frequency of testing?

Submitted  by KPR District School Board

A. Peterborough Public Health has made a recommendation via written submission to the Canadian Nuclear Safety Commission for additional soil testing and monitoring. This recommendation will be reiterated to commission members during our oral presentation at the public hearings for BWXT’s license renewal. It is ultimately the decision of the commission whether or not more sampling and testing is required. As the regulator, Canadian Nuclear Safety Commission is responsible to ensure that BWXT complies with all sampling requirements required as conditions of the facility’s operating license.

31 a. The Centers for Disease Control and Prevention notes that while external exposure to uranium is less dangerous than exposure to other radioactive elements, “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.” 1) Is this a credible source? Why or why not? and 2) Are you giving partial information and ignoring other possibilities with uranium? If so, why? Thank you.

Submitted by: King Street

A:

1. Yes, the Centers for Disease Control (CDC) is a credible source. The CDC uses the weight of evidence approach to inform their decision making and public communication.
2. Peterborough Public Health is sharing information regarding uranium as it is relevant to the current and proposed activities in Peterborough. We are not providing information on enriched uranium as this is not relevant to the Peterborough facility. Our focus has been on the actual products used on site, For BWXT in Peterborough, it is uranium dioxide.

For more information on the potential risks if BWXT starts producing pellets in Peterborough, please refer to question one.

32. The Agency for Toxic Substances and Disease Registry states that data on the toxicity of beryllium in children is limited to one case in 1948. It also states “Children are not small adults. They differ from adults in their exposures and may differ in their susceptibility to hazardous chemicals. Children’s unique physiology and behaviour can influence the extent of their exposure.” How can Peterborough Public Health conclusively say that beryllium levels are safe in the soil and air around this plant?

Submitted by: Charlotte St

A. The levels of beryllium found in the soil are about twenty times below the levels determined to have an impact on human health, based on a 2015 review of the science-based guidelines that have been in place since 1991. The measured air emissions from the facility are also well below the required regulatory and licence limits. Environmental monitoring and sampling are the best way to ensure that regulatory limits are being met and that the public is protected.

33. Would Peterborough Public Health ever acknowledge a statistically insignificant increase in cancers around the BWXT plant? In other words, would Peterborough Public Health acknowledge a single illness or death owing to BWXT’s activities?

Submitted by: Charlotte Street

A: The development of cancer is typically multi-factorial and is rarely linked to a single exposure. Cancer Care Ontario provides information on the various risk factors that contribute to the development of cancer. It also manages a cancer registry for the whole province, which can be used to calculate incidence rates. We can access that data, and we have, for example, to look more closely at the rate of mesothelioma, a cancer linked to asbestos exposure. In addition, we have worked with Cancer Care Ontario to examine whether there have been higher rates of cancers in neighbourhoods located close to industry. That analysis did not find an increased incidence of any cancer.

Often, increased rates of cancers are first noted in workers, who are usually exposed to higher concentrations of hazardous substances. Occupation is one of several risk categories for cancer. More information can be found in the Cancer Risk Factors Ontario: Evidence Summary report. Illness or death attributable occupational exposures associated with BWXT’s activities would be investigated by the Ministry of Labour and the Canadian Nuclear Safety Commission.

The Ontario Cancer Statistics 2018 report provides a chapter on cancer statistics by Public Health Unit. The report can be downloaded from the Cancer Care Ontario website, or by clicking here. Additionally, Cancer Care Ontario has also published a report on the Burden of Occupational Cancer in Ontario, which can be accessed by clicking here.

34. Do we know why the beryllium levels are increasing in the soil of Prince of Wales? (i.e. what is BWXT currently doing to contribute to this?)

Submitted by: Waterford Street

A: At this stage, we do not know why the beryllium levels are increasing in the soil at Prince of Wales school. Please refer to question 29 for more information.

35. Once the levels of beryllium found in the soil of Prince of Wales reach the limit of what is considered safe, what will happen to the students?

Submitted by: Waterford Street

A; It is the responsibility of the regulator to monitor compliance with the standards in order to ensure that levels are maintained below regulatory limits. In the event that the regulatory limits for beryllium in soil are exceeded and a health hazard is identified, Peterborough Public Health would investigate and take any necessary actions to protect the health of the students.

36. Are children more vulnerable to radiation?

Submitted by:  Gilmour Street

A: Avoiding unnecessary radiation of the thyroid during childhood and adolescence decreases the risk of papillary thyroid cancer. Even low-dose radiation of children from diagnostic imaging, for example CT Scans, should be minimized. Exposure to radiation increases the risk of thyroid cancer for decades after the exposure. (International Agency for Research on Cancer (IARC), 2020)

In addition, we know that children and adolescents exposed to UV radiation from the sun can be at greater risk for developing melanoma, a cancer of the skin. This is why the avoidance of direct sun or artificial tanning beds is important. Australia has been able to decrease the incidence of melanoma since 2007 by implementing policies and strategies to avoid sun exposure in young children. (IARC, 2020)

Even though uranium is weakly radioactive, it is not considered to be carcinogenic. Studies of people living close to uranium mines or mills have not found increased risk of cancer-related deaths.  Uranium’s main target is the kidneys. Kidney damage has been seen in humans and animals after inhaling or ingesting uranium compounds. There is no data demonstrating whether or not children are more susceptible to these effects (Agency for Toxic Substances and Disease Registry (ATSDR), 2013).

37. Where is the 12-page report mentioned in the Examiner (on Saturday February 8th) located on the website? I looked at the reports and data page but could not find it.

Submitted by: Waterford Street

A: The Staff Report to the Board of Health can be found within the February 12, 2020 meeting agenda by clicking here. Refer to pages 23 to 39.

38. In answer to a question about the proximity to the Prince of Wales School to the BWXT site “That it isn’t ideal.” How would you then go on to answer a concerned parent about to enroll their four-year-old next September, when they ask “What would you do Dr. Salvaterra?”

Resident of Hunter St W.

A: Parents should be confident in knowing that the environmental standards for uranium and beryllium are health protective, that available data has been reviewed and it demonstrates that BWXT emissions are well below these limits. PPH has recommended a more comprehensive environmental monitoring program to help reassure the community.

39. I live within the two-kilometre zone that BWXT considers the risk zone (an arbitrary and ridiculous boundary) and I am worried that uranium and beryllium carcinogenic particulate will be blown into my backyard and garden contaminating my food. The prevailing winds come my way from the BWXT site. I am appalled that the Medical Officer of Health deems small amounts of uranium and beryllium emitted from BWXT are safe because the articles referred to say so. They are not safe in any amount! Comparing these to background levels is a dangerous stance to take. And not all science is good. My skin specialist prescribes creams that will help alleviate symptoms, but will cause damage and potential skin cancer if used for too long. When I asked about natural alternatives, I was told, “we only promote what is scientifically proven.” So scientifically proven as a remedy, but one that can harm me. Is the Medical Officer of Health promoting low levels of toxic emissions, rather than suggesting alternatives to safeguard the health of Peterborough residents? I do not feel as though my health is a priority!

Submitted by: Euclid Ave.

A: Uranium is present in drinking water and food and small amounts are ingested and inhaled by everyone every day. It has been estimated that the average person ingests 1.3 µg or micrograms (0.033 Bq or becquerel) of uranium per day, corresponding to an intake of 11.6 Bq per year. It has also been estimated that the average person inhales 0.6 µg (15 mBq or megabecquerels) annually. On average, about 90 µg of uranium exist in the human body from daily intakes of water, food and air; approximately 66% is found in the skeleton, 16% in the liver, 8% in the kidneys and 10% in other tissues. The established regulatory limits are derived from the best existing evidence and are intended to be health-protective. Emissions from BWXT are well below these limits. Peterborough Public Health will continue to monitor annual compliance reports and results from the CNSC’s Independent Environmental Monitoring Program results to ensure that the community is protected.

40. Can you help me understand this infographic, prepared by the Environmental Protection Agency (USA), for the people of the Navajo nation, which says TWICE that Uranium exposure causes cancer? https://www.epa.gov/navajo-nation-uranium-cleanup/health-effects-uranium

Submitted by: Bolivar Street

A: The intended audience for this infographic is for people who have had high exposures to uranium from processes such as mining, exploring abandoned mines, living in a building built with materials from a uranium mine, or drinking contaminated water. The infographic shows the potential chemical effects and radiological effects as a result of exposure to high levels of uranium. For additional information regarding the understanding of the infographic, we would encourage you to contact the publisher, which is the United States Environmental Protection Agency.

41. I draw your attention to the Examiner’s “Uranium Exposure Not A Worry, Peterborough Public Health Report Concludes. Beryllium, the article notes, “has caused scarring of the lungs or lung cancer in factory workers who inhaled beryllium fumes or dust, the [Medical Officer of Health’s] report states. But there’s little chance of lung damage outside a workplace.” Why it is okay to hurt people inside a workplace? Are workers expendable?

Submitted by: Thomas Street

A: It is not okay to hurt people inside a workplace, nor are workers expendable. That is why there are specific occupational limits for exposure, which are regulated and enforced by Ontario’s Ministry of Labour.

Cancer Care Ontario has published a report on the Burden of Occupational Cancer in Ontario, which can be accessed by clicking here.

42. From the Examiner: “While heavy or prolonged uranium exposure can cause kidney damage, there’s no proof it causes other disease.” Why is kidney disease acceptable?

Submitted by: Thomas Street

A: Kidney damage is not acceptable which is why there are both occupational and public exposure limits for uranium in order to protect workers and the public to prevent kidney disease.

43. In touring the Toronto BWXT facility, will the team be considering potential outcomes at any point in the pelleting process of a systems fault? The nuclear industry is known for very efficient, tightly-coupled and complex systems with very little margin of error. This could mean that if there’s a fault in the system, it may be difficult for people on site to quickly identify the problem and prevent it from becoming catastrophic. Please consider the worst-case scenario should this occur. Meltdowns are happening in industries which have complex, tightly-coupled systems. This isn’t the type of thing that regular monitoring by the CNSC will be able to prevent. Thank you.

Submitted by: Hazeldean Avenue

A: During our tour, Peterborough Public Health learned that at the Toronto facility, fire officials and emergency responders review emergency response plans and potential incidents on an annual basis. BWXT frequently engages with fire and emergency services and conducts tours of the facility in order to educate responders and reassure them that a fire incident would not result in an exposure to radiation in excess of background levels. BWXT has conducted a safety case analysis and there are no known scenarios that would result in a criticality accident, which is an uncontrolled nuclear reaction. Safety Analysis Report Summaries for Peterborough and Toronto are available on the health and safety webpage of BWXT’s website.

44. The onus is on the medical officer of health, BWXT and the CNSC to prove that the uranium dust emitted by this plant is safe. Which studies of children specifically show that natural uranium or enriched uranium (which will likely be processed at this plant in the future) emitted by this plant will be safe for children?

Submitted by: King St

A. The current and proposed operations do not utilize enriched uranium and the facility is not licensed to use enriched uranium, therefore, only information regarding natural uranium is relevant. No fugitive dust is expected to be produced from the facility (please see the answer for question 3). Regarding the health-protectiveness of the standards for children, please refer to questions 18, 20, and 36.

45. What are the cumulative effects of natural uranium dioxide on the occupational health of women of reproductive age chronically exposed?

Submitted by Barbara Crescent

A. Canada’s Radiation Protection Regulations set limits on the amount of radiation that nuclear energy workers can receive. The effective dose limit for a nuclear energy worker (NEW) who is pregnant is much less than that for other nuclear energy workers. It is the responsibility of the NEW once she becomes aware that she is pregnant, to immediately inform the licencee in writing. The licencee must make accommodations for pregnant NEWs. The effective dose limit for a pregnant NEW decreases to
4 mSv for the balance of the pregnancy, once it is known, as compared to other NEWs where the effective dose limit is 50 mSv in a one-year dosimetry period. The reduction in the effective dose limit is to help ensure the fetus is protected.

The Toxicological Profile for Uranium provides the following information:
Limited data are available regarding reproductive effects of uranium in humans. Studies of uranium miners, millers, and processors found that male uranium miners had more first-born female children than expected, suggesting that uranium’s alpha radiation damaged the y-chromosomes of the miners. However, the workers were also exposed to 222Rn [an isotope of Radon], chlorine, hydrofluoric acid, lead sulfate, nickel, nitric acid and nitrogen oxides, silicon dioxide, sulfuric acid, tobacco smoke, and diesel exhaust. Uranium reduced fertility, likely due to reductions in spermatozoa counts, was observed in male mice exposed to ?5.6 mg U/kg/day in drinking water and mated with untreated females. However, fertility was not significantly affected in another study in mice in which males and females were treated by gavage with up to 14 mg U/kg/day. These apparently discrepant results may be due to the different mode of dosing between the two studies (i.e., gavage [tube-fed] vs. drinking water), which may have resulted in different rates of absorption. Uranium also reduced fertility in male rats dosed with 11.2 mg/kg/day and mated with untreated females; the NOAEL [no-observed-adverse-effect level] was 5.6 mg U/kg/day. Effects on female reproductive health have also been observed in mice orally exposed to uranium. Alterations in ovarian folliculogenesis [ovarian development/maturation] were observed at ?1.25 mg U/kg/day.

46. You have admitted that there’s not much data on the effect of beryllium on kids. You also admit that that enriched uranium is “much more likely to have an effect on health” and don’t acknowledge that BWXT and the provincial government have partnered with a private American company using a rector design requiring enriched uranium. However, you DO acknowledge that “The proximity to a public school is not ideal.” Should you not take a precautionary approach and say “No” to pelleting in Peterborough? Should you not put health before profit?

Submitted by: Homewood Avenue

A. Please refer to question 23.

47. Dr. Salvaterra what in your background and your education has qualified you to be an “expert” when it [comes] to risk assessment of emissions from a nuclear plant. Have you done a full comprehensive review of the emissions from the GE site. Until an independent review is completed I would suggest saying “At this moment I have insufficient information to comment” rather than “The fears I’ve heard expressed in the community are exaggerated and not based on science”. Have you have been put into a position of expertise by the Canadian Nuclear Safety Commission? The CNSC is not an independent body as they get 2/3rds of their funding from industry. What you say often sounds like CNSC jargon, for instance “natural uranium pellets”. Precisely in scientific terms what is natural about a uranium pellet? I also fear as there is to be an amalgamation of Health Units that you are under some pressure and might not be as independent as we might like you to be. From what I have heard over the last two months the Peterborough Health Unit should be doing a comprehensive health study of all past and present GE and BWXT [workers] and citizens living in the area immediately surrounding the plant. We have a health “bomb” waiting to go off in the city. I have talked to many, many people who have cancer and I suspect there is some significance that they either worked at the GE site, had a family member(s) who worked at the GE site or grew up in close proximity to the GE site. It will blow up and then we are all going to have to be accountable. Regardless of beryllium levels, uranium levels, etc. putting a nuclear facility with a 9,000 gallon of hydrogen, thousands of tons of uranium dioxide, being trucked in and out does not sound good for my health. This extended licence should be opposed for these reasons alone. The monitoring at this plant is so limited to being meaningless, the present safety precautions are not adequate for the workers now. BWXT gets around this by contracting workers rather than hiring them. The more I learn about this facility the worse it gets. All I can say is if you are going to defend them be very scientific because in the future I see a huge law suit coming from this facility. There are many well educated people who think this facility is in the wrong place. There are many people who continue to suffer as a result of working in or living in close proximity to this factory. We really need to take a good look of the cancer rates that are substantially higher than norms. I suspect we might have a higher smoking rate than other parts if the province but does this account for the statistical difference. There are many, many issues that need to be addressed. Our present and our future health will be impacted. Many citizens of Peterborough do not want the risk to our health of pelleting so that a multinational can make a huge sum of money. So I reiterate my primary question what in your background or education gives you the expertise to independently evaluate the emissions from a nuclear site?

Submitted by: Resident of Chemong Road

A. According to Ontario’s Health Protection and Promotion Act (HPPA), a medical officer of health shall investigate complaints regarding potential hazards related to occupational or environmental health in the health unit. In addition, the HPPA requires medical officers of health to stay informed on matters related to occupational and public health. With respect to the matter of the licence renewal at BWXT NEC Peterborough, PPH staff and executive have reviewed current literature and evidence, and have engaged with various parties including industry professionals, community members, CNSC staff, the Ministry of Environment, Conservation and Parks, the City of Peterborough, Public Health Ontario, as well as directly with BWXT staff, in order to become informed about this situation. When Peterborough Public Health reviews emissions from any industrial site, we consult with other provincial Ministries as appropriate, to make informed decisions to protect the public’s health.

48. Dr. Salvaterra what in your education and background makes you an “expert” on uranium and beryllium? The monitoring at the BWXT is highly questionable. Have you checked the testing methodology and independently verified the results? If you have not done this then I suggest you should be saying “I have insufficient information, no comment”. The CNSC is not an independent body as it is 2/3 funded by industry. Another question how natural is a “natural uranium pellet”. What is the scientific definition of the term “natural”? Have you done a health study of the former and present employees of the GE site their families and those living around the GE site? I talked to a woman two weeks ago who grew up near GE she has three different cancers, her father died of cancer and her mother is sick. I went to get my hair trimmed. The woman trimming my hair her father worked at GE he has cancer, her mother has cancer, her grandfather died of cancer. Another woman also cutting hair said she grew up on the road beside the GE parking lot and it is known that people on the street seem to have cancer. I have talked to so many people either related to the GE site or live around it. Is it just a big coincidence, could be, but perhaps not? You are responsible for the health of the following generations.

Submitted by:Benson Road

A. Please see previous question, 47.

49. Given that there is very limited research on the impact of beryllium on children, how can parents feel safe sending their children to POW? It is entirely feasible that children may be more sensitive than adults and are more likely to ingest soil on the play yard. Should the school board not be proactive on this issue? If levels continue to rise they will eventually become unsafe (if not already) and a retroactive response from the school board will have already put children at risk.

Submitted by Gordon Avenue

A. Please refer to the answers provided for questions 35 and 38.

50. Hello! I submitted a question a week or more ago, but don’t see an answer. How long does it usually take to get a response? Thanks!

Submitted by: Euclid Street

A. We are striving to post answers to questions received through this forum once per week.

51. Have you done any research on the school in Ohio that apparently was closed as a result of a BWXT operation? What are the facts of this case?

Submitted by: Street

A. The closure of this school was in response to the detection of enriched uranium. The Portsmouth Gaseous Diffusion Plant located nearby the school that enriches uranium for use in the US nuclear fuel and weapons industries. Uranium is not enriched in Canada. Furthermore, the facility in Ohio uses a gaseous form of uranium, which does not occur in Peterborough. Therefore, from a risk or hazard perspective, the Portsmouth Gaseous Diffusion Plant should not be compared to the BWXT facility in Peterborough.

52. The legacy GE operation in Peterborough first became involved in Canada’s nuclear industry in 1955. BWXT has maintained that involvement since 2016. So Peterborough has been hosting a nuclear industry operation for 65 years. From an epidemiological viewpoint, what has been the legacy of those decades of involvement, supplying and manufacturing on the health of residents along streets adjacent to the plant? Is there a cancer bubble along Wolfe, Albert and Paterson streets? This is of course a difficult question as it is widely acknowledged that there is a range of carcinogenic contaminants on the GE site, including PCBs, assorted toxic cleaners and solvents. That being said, should PPH do an epidemiological survey of these neighbourhoods prior to the commencement of any new nuclear manufacturing so a baseline could be established for future evaluation? Thanks for hosting this Q & A board…

Submitted by: Boswell Avenue

A. The development of cancer typically depends on a number of factors and is rarely linked to a single exposure. Cancer Care Ontario provides information on the various risk factors that contribute to the development of cancer. It also manages a cancer registry for the province, which is used to calculate incidence rates. Peterborough Public Health uses this data and has accessed it, for example, to look more closely at local rates of mesothelioma, a cancer linked to asbestos exposure. In addition, we have worked with Cancer Care Ontario to examine whether there have been higher rates of cancers in neighbourhoods located close to industry along Monaghan Road. That analysis in 2012 did not find an increased incidence of any cancer.

Cancer is the leading cause of death in Ontario, accounting for approximately one-third of all deaths in this province. Age standardized cancer incidence rates for Peterborough Public Health are comparable to Ontario, with the exception of higher rates of lung cancer in males and females. The Ontario Cancer Statistics 2018 report by Cancer Care Ontario provides a chapter on cancer statistics by geography, and this is available on www.peterboroughpublichealth.ca under the Reports & Data section. Additionally, Cancer Care Ontario has also published a report called Burden of Occupational Cancer in Ontario available at www.occupationalcancer.ca.

While occupation can be a risk factor, most cancer deaths are not related to occupational exposures. According to the Centers for Disease Control and Prevention, it has been estimated that 3-6% of all cancers worldwide are caused by exposures to carcinogens in the workplace. A good summary of the provincial context can be found in Cancer Care Ontario’s Cancer Risk Factors Ontario: Evidence Summary report.

53. Given that, from UNSCEAR ( 2016), “there is no reason to consider that alpha particles from uranium will have different relative effectiveness from alpha particles of similar energy emitted by other radionuclides (e.g. 222Rn and 239Pu [M12]),” shouldn’t we take a more precautionary approach to public health?

Submitted by:  Bolivar St.

A. Please see the answers to questions 18, 21, and 39.

54. Shouldn’t we take a precautionary approach given the following and that there is an Elementary School virtually across the street from BWXT?
UNSCEAR (2016):Uranium worker data have often been limited to studies of male Caucasians. Quantitative generalization to women or other population groups is therefore uncertain. No occupational studies have attempted to examine genetic, epigenetic or metabolic susceptibility factors for uranium related diseases. Worker studies also provide no information about children, who may be more susceptible to the effects of uranium exposure than adults.

Submitted by: Bolivar St.

A. Please see the answers to questions 1, 16, 18, 36 and 37.

55. Is Dr. Salvaterra sticking by her original but inaccurate statement to City Council that there are only known occupational cases of beryllium disease (either beryillosis or CBD) or is she willing to acknowledge to the public that according to several research studies since 1949 there are “neighbourhood cases“ of beryllium disease in people living in the close vicinity of plants that process beryllium such as BWXT?

Submitted by: Charlotte St

Although it is unclear which studies this question is specifically referring to, based on studies that we have reviewed, the studies explored cases of berylliosis (or chronic beryllium disease) from 1949 to 1969.  These are studies of communities surrounding beryllium manufacturing facilities involved in the manufacture of beryllium oxide, alloys and metal, and the production of beryllium tools and metal products. Chronic berylliosis can occur at lower concentrations. It is a chronic inflammatory lung disease that causes scarring (fibrosis) and localized inflammatory lesions (granulomas) in the lungs. It is very similar to sarcoidosis, which causes the same signs and symptoms, in the absence of beryllium exposure. Chronic sustained air concentrations associated with the development of chronic berylliosis are 0.52-1.2ug/m³ (roughly 50-100 times the Ontario AAQC, or 10-24 times the Ontario Occupational Exposure Limit of 0.05ug/m³).

Acute berylliosis was documented in historic settings (1950s) where exposure to high levels of soluble beryllium compounds (in a beryllium extraction, processing, and fabricating facility, where levels were >0.1mg/m³), led to (in some cases) progressive upper and lower respiratory tract symptoms (e.g. stuffy nose and sneezing, or cough and shortness of breath), and in a small number of severe cases, death. For comparison, these concentrations are approximately 10,000 times higher than the Ontario Ambient Air Quality Criteria limit of 0.01ug/m³, and 2,000 times the Ontario 8-hour occupational exposure limit of 0.05ug/m³. In the decades since implementation of better environmental and workplace controls, such outcomes have not been seen, except in rare accidents.

Please also refer to the answer for question 28.