Uranium News May 16, 2009

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URANIUM NEWS

MAY 16, 2009

IN THIS ISSUE:

1) NO URANIUM ANTI-NUCLEAR SHOW
2) ARTICLE: GROUP TO KEEP PROTEST ALIVE
3) QUEEN'S PARK PROTEST RALLY
4) BEDFORD MINING ALERT 10TH ANNUAL GENERAL MEETING
5) BILL 173: ONTARIO MINING ACT AMENDMENTS
6) CCAMU MEMBERS ASK FOR SUPPORT FOR PROPOSED ACT TO REGULATE ACTIVITIES IN AREAS WITH ELEVATED LEVELS OF URANIUM
7) ARTICLE: SHERMAN EXPLAINS
8) ARTICLE: NUCLEAR ASSOCIATION SHOULD BE MORE RESPECTFUL ABOUT ALTERNATIVES
9) LETTER: NUCLEAR PLANTS ARE NOT JUST COSTLY TO BUILD
10) LETTER: FARE'S RESPONSE TO CNSC HEARING ON SYNTHESIS REPORT

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1) NO URANIUM ANTI-NUCLEAR SHOW

Remember to mark your calendars for the…

No Uranium Anti-Nuclear Art Show

Please join us Sunday, May 31, 2009, 3 – 5 pm at the Maberly Hall, just north of Highway 7 between Perth and Sharbot Lake.  Fifteen artists will be showing their work about their resistance to uranium exploration and mining.  Sculpture, murals, photos and paintings will be on display to encourage contemplation and conversation and conversion to ecologically sensible energy options.  There will be several short films by local filmmakers and performances by spoken word poets.  Light refreshments will be served.

The show will also be displayed July 10th – 12th at The Art of Being Green Festival at the Middleville Fair Grounds.

Contact by reply to UNews for more info.

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2) ARTICLE: GROUP TO KEEP PROTEST ALIVE

By Paul Schliesmann

Monday, May 11, 2009

http://www.thewhig.com/ArticleDisplay.aspx?e=1562022

Opponents of a proposed uranium mining operation near Sharbot Lake say changes to Ontario's Mining Act will not halt their two-year battle.

"No, not at all," said Lynn Daniluk of the Community Coalition Against Mining Uranium. "We have actions planned through out the summer. We have no intention of letting it rest.

"(The changes) didn't cover uranium."

The community coalition joined forces with native bands in the Sharbot Lake area in 2007 to put a stop to a uranium operation proposed by Frontenac Ventures Corporation.

The groups were concerned about potential negative effects on the environment and the health of people living in the area.

Demonstrations and blockades last year led to arrests former Ardoch Algonquin First Nation chief Bob Lovelace spending three and a half months in jail.

In an e-mail from Ecuador last week, Lovelace said the Ontario government has missed a chance to making meaningful changes through Bill 173.

"For all the hype around what the government might have done and the real opportunity that was before them, I think we need to be disappointed," he wrote to the Whig-Standard.

"Change to the legislation does not take place often and what has been proposed does not nearly extend rights to Ontario citizens or recognize Aboriginal title in a way that will avoid conflict and assure that mining practice will be improved."

In December, the Shabot Obaadjiwan, the Snimikobi Algonquin and the Algonquins of Ontario broke away from their protest partners and signed an agreement with Frontenac Ventures and the Ontario government to allow exploratory drilling at the site.

The recent changes to the mining act, which will require wider consultation with aboriginal communities as well as a process to settle disputes, are being touted as ways to avoid similar standoffs in the future.

"I think they've done it. The important stakeholders are speaking well of it," said Victor Pakalnis, the Kimross professor in mining and sustainability at Queen's University.

Pakalnis described the current act as "very archaic."

"It has caused a lot of conflict with landowners and particularly aboriginal communities in the north."

He said the provincial government had to protect the rights of property owners and aboriginal people while also paying attention to the public wealth that is created by mining.

"This is a substantial royalty that goes to the province. You want to benefit from the fact that Canada is a rich country from a mineral point of view," he said.

Marilyn Crawford of the community coalition said one of the positive changes in Bill 173 is that private lands without claims on them cannot be staked. In Bedford district of South Frontenac Township where she lives, however, there are 34 existing claims on private property that will remain in effect.

Though aboriginals must now be consulted about mining proposals, Crawford said they will have no veto power.

"There's a lot of work to be done," she said. "There's no consideration to uranium and the impact on health and the environment. It's treated the same as any other mineral."

Pakalnis said that if proper safeguards are put in place uranium mining can be safe, pointing to the fact that a uranium operation once existed in the Bancroft area.

"You can mine safely, extract the mineral and leave behind an environmentally responsible area for after the mine is finished," he said.

Daniluk, however, remains skeptical.

"It's radioactive. We're not talking about a gravel pit or even a silver or gold mine," she said. "They don't last 4.5 billion years. Some of the products left behind in the (uranium mine) tailing ponds are toxic for 4.5 billion years.

"If someone has evidence that uranium mining is safe, I'd like to see it. There isn't one uranium mine in Canada that hasn't had serious consequences for the community."

Article ID# 1562022

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3) QUEEN'S PARK PROTEST RALLY

Date: Sunday, September 27, 2009
Time: 2:00-4:00
Place: Queen's Park Toronto

Organized by Cottagers against Uranium Mining and Exploration (CUME)
Cottagers...@sympatico.ca   www. fighturanium.com/cume.html

Stop Uranium Mining and Exploration. Demand a legislated Ban for Ontario like the one granted in British Columbia

“The mining and milling of uranium ore produces very large volumes of long-lived, low-level radioactive tailings which have leached into waterways in the vicinity of Elliot Lake, Ontario, thereby posing serious health and environmental problems.”  Ontario Royal Commission on Electric Power Planning ‘Porter’ Report

“Radioactive fallout and washout from uranium mining sites is carried for up to 400 kilometres resulting in a significant increase of cancer fatalities in a wide area.”  Kueppers 1994

Join this community-wide gathering, hear excellent speakers and enjoy musical interludes.

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4) BEDFORD MINING ALERT 10TH ANNUAL GENERAL MEETING

Bedford Mining Alert 10th Annual General Meeting
Time: 10:00 am Saturday July 25, 2009
Location: The Bedford Town Hall
(1381 Westport Road approximately 8 km east of Godfrey)
Featuring: Senior Official from the Ministry of Northern Development and Mines
Discussion and Questions about Bill 173 - the Mining Amendment Act

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5) BILL 173: ONTARIO MINING ACT AMENDMENTS

To review Bill 173, the Act to amend the Ontario Mining Act, go to,

http://www.ontla.on.ca/web/bills/bills_detail.do?locale=en&BillID=2170


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6) CCAMU MEMBERS ASK FOR SUPPORT FOR PROPOSED ACT TO REGULATE ACTIVITIES IN AREAS WITH ELEVATED LEVELS OF URANIUM

Description of the Request to the Environmental Commissioner of Ontario
by Marilyn Crawford and Wolfe Erlichman, March 31, 2009
The request is to review the need for a new Act to regulate mineral exploration and residential/industrial development in areas where elevated levels of uranium have been identified.
This will require a review of relevant existing legislation that offers protection to the environment from elevated levels of uranium. It will require a review of the impacts of bedrock disturbing developments on the release of radiation and related toxins in uranium zones and the implications on the environment and health. A comparative review of legislation in other jurisdictions will assist in identifying both the need for protection from negative impacts and to serve as examples for needed regulations The review would further consider the need to provide opportunities for open, meaningful and consultative processes when making decision about projects that may have significant adverse effects on the environment, socio-economic health of communities, and projects that will cause significant public concern. Considering that exploration for uranium is taking place in several locations in Ontario, it is important to have an Act in place that both protects the environment and requires a public review prior to advanced exploration and development of a uranium mine.
Description of the New Act:
To enforce collaboration on high risk, multi-facetted concerns with health, safety and environmental issues related to uranium, there would be involvement with several Ministries, specialists, experts and civil society to develop the Act. There would be opportunity for comment on the Act via the Environmental Bill of Rights.

The Act would:
1.      follow the principles of precaution  as opposed to ‘low risk’.
2.      require conformity to the Act.
3.      establish priority of the Act (ahead of the Mining Act) for exploration projects.
4.      regulate exploration for uranium and other minerals in areas with known elevated levels of uranium. A map of a uranium zone is included in the review.
5.      regulate other types of development, such as developments that would include bedrock excavations and drilling of multiple wells for residential and industrial expansion.
6.      regulate projects where the potential adverse effects are not predictable.
7.      regulate projects that are likely to cause significant adverse ecological and socio-economic effects.
8.      protect against increased levels of uranium in groundwater through human causes.
9.      prohibit mechanical exploration, including drilling and trenching, near private wells.
10.     prohibit exploration for uranium in surface water-supply watersheds.
11.     include provisions for mandatory testing of well water in uranium sensitive areas.
12.     regulate projects that are likely to arouse significant public concern from the impacts of release of naturally occurring uranium.
13.     outline a process for accessing and reviewing public concerns.
14.     require transparency through public access to documents related to projects.
15.     require comment on relevant project proposals on the Environmental Bill of Rights.
16.     ensure that the public is aware of and will have input into decisions that would have an impact on them.
17.     establish an Independent Commission or Review Committee/Board with:
a.      representation from a cross section of civil society
b.      the authority to review relevant project proposals
c.      a mandate to assess the environmental and socio-economic impacts of  project proposals.
d.      have the authority and requirement to receive and consider concerns, comments and suggestions about project proposal applications in areas of known occurrence of uranium.
e.      the authority to reject projects.

The request asks Ministries to undertake the review to protect the environment and take into account the impacts on human health through ground and surface water, soil and airborne contaminants. This requirement is in consideration of the toxic accumulating effects of uranium when unleashed from its geological presence through human causes such as bedrock excavations and drilling for residential, commercial, exploration and mining developments. Unearthed uranium when exposed to the atmosphere decays into its various toxic daughter products (other isotopes) over time thereby getting into the environment and food chain. This occurs in the air as dust and heavy gas (radon) as well as leaching into the surface water or groundwater thereby contaminating water sources that may provide drinking water and wildlife habitat. There should be a review to protect future generations.

The request states that exploration for uranium is a contentious issue in Ontario, producing conflicts between mining interests, government and local communities. There should be a review to protect the environment and to resolve issues around exploration and development in areas where uranium has been identified.

The application includes the following summary and details of deficiencies:
•       Public participation and consultation
•       Mineral Exploratory Regulatory Regime in Ontario
a) Provincial Versus Federal Jurisdiction over Mineral Exploration
b) the initiative to modernize the Ontario Mining Act
c) Limitations of the Assessment Work Regulation- the unique nature of uranium
d) Preliminary Exploration and other Environmental Authorizations
•       Environmental Assessments and Land Use Planning
•       Uranium and Drinking Water
•       The Clean Water Act
•       Uranium and Drinking Water
•       Uranium Drinking Water Quality Standards
•       Uranium Exploration: Potential Contamination of Water from Uranium
•       Direction to municipalities, when developing Official Plans, to consider impacts of developments on human health and the environment in uranium areas

The applicants are concerned that continued or expanded exploration for uranium and an influx of new residents into areas could put the public at risk. Large, local development and expansion of towns and hamlets in uranium areas leading to an increase in population would create more excavations and well drilling with the potential of increasing exposure to uranium over time.

By undertaking a review and establishing a new Act, the Ontario Government could play a vital role in being a provincial government trend-setter in the health, welfare and environmental aspects with regard to the management of uranium zones in the Province.


LETTER TO POTENTIAL SUPPORTERS
This email is to give an update on our application for a review of the need for a New Act to legislate activities in areas where elevated levels of uranium has been identified. The request was received by the Environmental Commissioner of Ontario on April 3 and referred for review to the Ministry of Northern Development and Mines (MNDM), Ministry of Municipal Affairs and Housing (MMA&H), Ministry of Natural Resources (MNR) and the the Ministry of the Environment (MOE) for consideration. The request was also sent to the Ministry of Energy and Infrastructure (ME&I) and the Ministry of Health and Long-Term Care (MH&LTC) as a non-prescribed review.
Under section 67 of the EBR, each Ministry must consider an application in a preliminary way, as well as any submission from a person who may be directly interested in the review. The Ministries may also consider any social, scientific or other evidence that is relevant.
In June, four Ministries will provide a written decision whether a review will be conducted.
Thank you to those who have already sent submissions. This will serve as a reminder to others that there is an opportunity to provide information to Ministers showing why a review should be undertaken.
Please note that Bill 173, introduced in Ontario parliament April 30 to modernize Ontario’s Mining Act, does not give special consideration to exploration for uranium, non-aboriginal consultation and provisions for environmental assessment.
Information can be sent to one or more of the Ministers listed below and copied to the Environmental Commissioner. Included could be information such as: limitations of existing legislation to protect public health/safety and the environment, fact sheets, research and position papers, descriptions of concerns/issues, reports, to offer support for our request or to offer solutions, such as establishing a moratorium on uranium exploration.
Although requests to the ECO are limited to Ontario residents, people from outside of province may send information to Ministers for consideration. Please reference your comments to file numbers R2009001 (MNDM),  R2009002 (MMA&H) R2009003 (MNR), and R2009004 (MOE).  Please copy the Environmental Commissioner and the Minister of Ministry of Energy and Infrastructure and the Ministry of Health and Long-Term Care.
Your submissions should be made as soon as possible. Your input will show that there are a range of complex issues that need to be considered and addressed.
Regards,
Marilyn Crawford and Wolfe Erlichman
Contact list:

Hon Michael Gravelle
Ministry of Northern Development and Mines
Room 5630, 5th Floor, Whitney Block
99 Wellesley Street West
Toronto, Ontario M7A 1W3
mgrave...@liberal.ola.org
fax: 416-327-0665
file # R2009001
----------------------------
Hon Jim Watson
Ministry of Municipal Affairs and Housing
17th Floor
777 Bay Street
Toronto, Ontario M5G 2E5
jwats...@liberal.ola.org
fax: 416-585-6470
file # R2009002
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Hon Donna H. Cansfield
Ministry of Natural Resources
Suite 6630, 6th Floor, Whitney Block
99 Wellesley Street West
Toronto, Ontario M7A 1W3
dcansfi...@liberal.ola.org
fax: 416-325-5316
File number R2009003
--------------------------------
Hon John Gerretsen
Ministry of the Environment
12th Floor
135 St. Clair Avenue West
Toronto, Ontario M4V 1P5
jgerret...@liberal.ola.org
fax: 416-314-6748
File number: R2009004
----------------------------
Hon David Caplan
Ministry of Health and Long-Term Care
10th Floor, Hepburn Block
80 Grosvenor Street
Toronto, Ontario M7A 2C4
dcapl...@liberal.ola.org
fax: 416-326-1571
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Gord Miller, Environmental Commissioner of Ontario
1075 Bay Street, Suite 605
Toronto, ON M5S 2B1
Fax: 416-325-3370
E-mail:  commis...@eco.on.ca

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7) ARTICLE: SHERMAN EXPLAINS

Book review By Ursula Pflug, Special to the Examiner

May 9, 2009

Paula Sherman was in the news last year when she and fellow professor Robert Lovelace were arrested for protesting the exploratory drilling for uranium by Frontenac Ventures Corp. near Sharbot Lake in rural eastern Ontario.

In the first section of her new book, Dishonour of the Crown: The Ontario Resource Regime in the valley of the Kiji Sibi, Sherman describes the events leading up to their arrests as well as the details of the court cases and the Ardoch position that the province handing out drilling permits at all was unconstitutional.

To read the rest of this article go to,
http://www.thepeterboroughexaminer.com/ArticleDisplay.aspx?e=1561064

Dishonour of the Crown: The Ontario Resource Regime in the Valley of the Kiji Sibi By Paula Sherman

Foreword by Leanne Simpson Arbeiter Ring Publishing $12.95 88 pp.

ISBN: 978-1-8904037-36-5

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8) ARTICLE: NUCLEAR ASSOCIATION SHOULD BE MORE RESPECTFUL ABOUT ALTERNATIVES

The Huntsville Forester

May 13, 2009

"Mr. Colin Hunt, The director of research at the Canadian Nuclear Association, replied recently to a letter I had written outlining alternatives to nuclear for producing electricity. I felt a genuine sense of discontent last week while reading his accusations that I had included “a significant number of factual errors.”

In principle, I applaud him for challenging my opinions, yet I have many problems with his dismissive nature of the options that were presented.

Mr. Hunt completely rejected the idea that Germany’s total wind capacity matches that of Ontario’s total electrical needs, and he cited some numbers from 2007. Here are the genuine updated facts: At the end of 2008, Germany had 23,903 MW of wind power generation. Throughout this present month of April, Ontario’s peak demand will never rise above 18,000 MW. Furthermore, Mr. Hunt needed to realize that residents of Muskoka are intelligent enough to know that wind is only part of the puzzle, and would never assume that this statistic is to imply that Ontario will go wind alone."

To read the rest of this article go to,
http://www.huntsvilleforester.com/article/135640


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9) LETTER: NUCLEAR PLANTS ARE NOT JUST COSTLY TO BUILD

Nuclear plants are not just costly to build, they are also expensive to operate.   Put aside for a minute the billion dollar repair bills and take a look at the salaries of Ontario Power Generation’s employees released under Ontario’s “sunshine” law requiring public entities to report incomes over $100,000.

In 2008, approximately 57% of OPG employees made more than $100,000 (click here for the full list <http://www.cleanairalliance.org/resource/OPG-Salaries-2008.xls> ).  Reading through the list of close to 7,000 employees making more than $100,000, you will quickly see that the majority are involved in the company’s nuclear operations.  At the top of the list is OPG CEO Jim Hankinson, who made $2.475 million (that’s 17 times the annual budget of the Ontario Clean Air Alliance).

Nuclear’s bloated costs may be good for those working for OPG, but the rest of Ontario’s residents would be far better off if we replaced nuclear with lower-cost hydro imports from Quebec.  Quebec has the power, but Ontario seems to be too busy preparing to write big blank cheques to nuclear companies to pursue the lowest cost options for the province’s consumers.

Please pass this message on to your friends.

Thank you.

Jessica Fracassi, Communications & Membership Director
Ontario Clean Air Alliance
402-625 Church St, Toronto M4Y 2G1
Phone: 416-926-1907 ext. 245
Fax: 416-926-1601
Email: jes...@cleanairalliance.org <mailto:jes...@cleanairalliance.org>
Website: www.cleanairalliance.org <http://www.cleanairalliance.org/>
Website: www.OntariosGreenFuture.ca http://www.ontariosgreenfuture.ca/

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10) LETTER: FARE'S RESPONSE TO CNSC HEARING ON SYNTHESIS REPORT

Families Against Radiation Exposure
P.O. Box 202  Port Hope, ON   L1A 3W3

May 12, 2009

Michael Binder
Chairman and CEO
Canadian Nuclear Safety Commission
280 Slater St.
P.O. Box 1046, Station B
Ottawa, ON K1P 5S9

Dear Mr. Binder:

In this letter we demonstrate to you, and to the citizens of Port Hope and the public at large, that the conclusion of your staff that Port Hope is safe from the nuclear industry does not stand up to scientific scrutiny.

The April 29 meeting of your Commission in Ottawa made it quite clear that the information your staff presented in its “Synthesis Report: Understanding Health Studies and Risk Assessments Conducted in the Port Hope Community from the 1950s to the Present” does not support the Report's own conclusion that our community here in Port Hope is not at any risk because of the operations of the nuclear industry in the past, present or future.

You and some of your staff at that meeting made a number of scientific blunders and assumptions that are embarrassing to the public esteem of the CNSC and its commissioners, mislead the citizens of Port Hope, and ultimately bring disrespect to the CNSC.

F.A.R.E. is very respectful of the dignity of the hearing process and has taken steps to consult an academic adviser, who is a geneticist and who watched the April 29 meeting on webcam. We have since reviewed the transcript of the meeting, in order to substantiate our concerns below.

It is also not clear from the transcript what action the Commission took on two key recommendations of staff – that this document should stand as a “primary reference” on the state of health of people who live in Port Hope vis a vis the nuclear industry; and that no further health studies need to be done. Previous experience suggests that unless staff are told otherwise, they proceed on the assumption that their recommendations have been approved.

This causes us great concern, because we feel the "Synthesis Report" itself is deeply flawed and relies on unwarranted assumptions. We trust that you will give us a proper explanation for the following evident blunders by you and your staff, and provide the public with appropriate corrections of the misinformation that was dispersed at the hearing.

1.  The “No Threshold” Principle – the scientific fact that there is no level of radioactivity so low that it does not cause genetic mutation which can result in cancer.

Possibly the most embarrassing of the many scientific blunders was when you, as president of the country’s commission on nuclear safety admitted, and then demonstrated, that you do not understand the fundamental health-safety principle of radioactivity – that there is no safe dose.  This has been known to scientists for 70 years.

You said that you do not understand the term “No safe level of radiation” and you went on to ask, as if you found the idea absurd, whether this means that the background radiation is not safe.

Yes, Mr. Binder, it means exactly that.  We are disturbed to learn that it is necessary to explain this fact about nuclear energy to the president of the Canadian Nuclear Safety Commission ... but better late than never.

All radiation, even in minute doses, can and does cause damage to the genetic material, DNA.  This damage is called mutation. Virtually all mutation is harmful and much of it causes cancer.  Just as there is something called “background radiation,” so too there is something called “background (spontaneous) mutation rate.” This is the frequency with which mutation occurs in the population, as a result of “background” radiation and other non-specific effects.

While we are surprised to discover that you did not know this, we are happy to be able to provide what is evidently new information to you.

Relevant scientific references concerning the “No Threshold” Principle are provided in the list of References given below. For the original research work see Muller HJ (1939); Ray-Chaudhuri SP (1939).  For more recent work see Nussbaum RH (1998);  Wakeford R (2002).

The web site of UNSCEAR (United Nations Scientific Committee on the Effects of Atomic Radiation) states:  “Consensus reports by the United States Research Council and the National Council on Radiation Protection and the United Nations Scientific Committee on the Effects of Atomic Radiation  (UNSCEAR) [web sites given in list of References below] have upheld the Linear No Threshold model (LNT), concluding that radiation is dangerous no matter how low the exposure and discounting the existence of radiation hormesis in humans.”  (Hormesis is the discredited claim that radiation exposure can be beneficial).

2. The known cancer-producing effects of low levels of radiation.

Closely rivalling our surprise at hearing your pronouncements on the “No Threshold” Principle was our unpreparedness for the remarks by Dr. Patsy Thompson, the CNSC’s Director-General of Environmental and Radiation Protection and Assessment, and presumably lead author of the "Synthesis Report", indicating that she evidently knew of no studies that have ever shown health effects of low-level radiation.  She stated that when the scientific literature refers to low doses of radiation, the doses they are referring to "are in the hundreds of millisieverts" (emphasis added by us).

It has been known for over half a century that a single X-ray given to a pregnant woman (a dose of about 10 millisieverts) can cause leukaemia in the baby that was exposed as a fetus in the womb (Stewart et al., 1956: Stewart et al., 1958).

In case any CNSC personnel are tempted to cite work by the famous Sir Richard Doll and co-worker Court Brown, with Bradford Hill, which disputed those original findings, we mention that Doll later recanted that opinion, admitting that the work with Court Brown had been “not very good,” that the results were “unreliable,” that the study “was too small” and that he had “never been happy with that study.” The original findings of Stewart and colleagues were confirmed and reinforced by a large study by MacMahon in 1962 (see Reference list), and later by many others including R. Doll himself in 1997.

The latter concluded, in an article with R. Wakeford, in 1997, that a dose of the order of 10 mGy (equivalent to about 10 millisieverts) received by the fetus causes a consequent increased risk of 40% for childhood cancer, and that the results of their study “strengthens belief in the idea that there is no threshold dose below which no effect is produced” (Doll and Wakeford, 1997).

Since CNSC appears to have been unaware of the above, it is possible that this information may give CNSC co-workers the impression that cancer from low-level radioactivity concerns only fetuses.  We mention therefore, as just one example amongst many reports on cancer in workers in the nuclear industry, the Hanford study (Mancuso et al., 1997).  This study is well known also for the pernicious persecution of the researchers by U.S. government agencies, because of the scientists having exposed the risks of the industry, even at low levels of exposure.  This notorious tradition of persecution is a very disturbing fact of the history of radiation research (Hardell et al., 2007; Nussbaum, 2007).

The literature is rife with reports on cancer-producing mutation at low levels of radiation (e.g. also Nussbaum and Koehnlein, 1994).  It is astonishing and unacceptable that your senior CNSC spokesperson publicly declared herself unfamiliar with these facts at your meeting on April 29.

3.  Citations in the “Synthesis Report” showing significantly elevated frequencies of diseases, including cancer, in Port Hope, compared to other areas.

In response to the "Synthesis Report" FARE's written Submission (which we will refer to as FARE's Submission) cited verbatim comments from the Report which indicated the occurrence in Port Hope of various diseases, in frequencies statistically significantly higher than in the control areas that the Port Hope figures had been compared to.
The list included statistically significant elevated frequencies of:

"Coronary heart disease and cirrhosis of the liver";
"Male lung cancer";
"Influenza and female skin infections";
"Cancers of the pharynx";
"Lung cancer (trachea, bronchus and lung)";
"Lung cancer in women";
"Cancers of the nose and sinuses";
"Excess nose and sinus cancer";
"Childhood brain and nervous system cancer";
"Circulatory disease, cancer and respiratory disease";
"Brain and nervous system cancers in women";
"Lung cancer";
"High blood pressure (hypertensive disease)".

It did not escape the notice of at least some Commissioners that the "Synthesis Report" had not accounted for these data.  In response to a question by Dr. McDill on this issue, Dr. Thompson gave the astonishing answer that “there are elevated diseases but we also make the comment that these diseases are not associated with radiation doses at those levels of uranium or other contaminants...”

This appears to have satisfied you, as President, and the CNSC as the official body designated to care for the Nuclear Safety of the nation.  We might naively have thought it unnecessary, but now realise it is indeed necessary, to point out to the CNSC that:

a)  This list contains repeated mention of numerous cancers.  For anyone even peripherally in contact with the issue it is well known, or should be, that radioactivity is causative of cancer.  It is unacceptable for a senior CNSC official to brush aside these data with the off-hand comment that we say "these diseases are not associated with radiation....”

b)   With respect to the non-cancer diseases in this list, and other long lists of diseases known to be abnormally frequent in Port Hope, the following applies:  If a disease occurs in excess numbers in an area of high exposure to a cancer producing agent, both good science and good ethics dictate that the compelling and imperative working hypothesis is that there is a causal relationship, until proven otherwise.  That there may be no previous proof of a relationship is most probably because no adequate studies have been done.

This cannot come as a surprise --  there are probably no sites in the world that have as great exposure to radioactivity in residential urban areas as Port Hope, and certainly no adequate studies of these diseases have been done here.

It is relevant to add here that the "Synthesis Report" makes no mention of other studies that have shown statistically significantly increased frequencies of diseases including cancers in Port Hope.  In one study alone, titled "Great Lakes Health Effects Program: Port Hope Harbour Area of Concern: Health data and statistics for the population of the Region (1986-1992)", over 40 diseases are listed in which either mortality or morbidity numbers were higher in Port Hope than in the areas being compared.

As we indicated in our Submission, we have previously brought these and other similar data to the attention of the Mayor of Port Hope, and pointed out the fact that she has misled the citizens in telling them that existing studies show no health problems in Port Hope. Your "Synthesis Report" perpetuates this misinformation.  Furthermore, in releasing your "Synthesis Report" in Ottawa instead of in Port Hope, without any opportunity being offered to us or other concerned citizens to respond, you sent the clear message that input from Port Hope citizens would not be welcome, thus reinforcing the Report's conclusion that essentially no further discussion on the issue will be entered into by CNSC.   When we heard of the scheduled release in Ottawa, we requested and received the opportunity to participate.   The Mayor of Port Hope immediately received permission to also appear, and she used the opportunity to echo the Report's message that there is no problem. Thus both CNSC and the Mayor and Council of Port Hope are denying the facts that are clearly revealed in our Submission and explicitly summarised above.  The data are being brushed aside.  To err on the side of complacency rather than on the side of caution, as the CNSC has done here, is unconscionable.

Port Hope citizens legitimately demand that the CNSC distance itself from the comments made in the "Synthesis Report", and instead take immediate action to deal with the fact that there is a large number of diseases that have been shown to have occurred in excess in Port Hope, that the list includes cancers of various types, and that a causal relationship to the nuclear pollution is presumed until proven otherwise.  We feel the time has arrived when the public must be informed of the facts.

4.  Statistical significance.

In the context of the above-mentioned long list of diseases, including cancers, that have occurred in statistically significantly increased frequency in Port Hope, a question from the floor raised the issue of a previous review of the Port Hope problem by Dr. Eric Mintz, a distinguished professor of epidemiology, commissioned by the CNSC.  Dr. Mintz had found problems in Port Hope, but curiously this report, done for the CNSC, was not mentioned in the "Synthesis Report".  Almost incredibly, the explanation for this given by Ms. Rachel Lane, CNSC Staff Epidemiologist, was that "the CNSC does not agree with" Dr. Mintz.  Thus results that the CNSC does not agree with are excluded from consideration.

Ms. Lane did give further explanation.   She stated that "Dr. Mintz makes very basic misinterpretations of statistical concepts and epidemiological methods", and that he was dealing with small numbers, on which "any epidemiological university book on epidemiology" (sic) advises "to take great caution".  Indeed, she went on to point out, as if in criticism, that the numbers were often small, and that a difference of one or two cases can make the difference between highly statistically significant and not significant.

This demonstrates a deeply concerning misunderstanding of the concept of statistical significance on Ms. Lane's part.  As anyone who understands the concept knows, the techniques for determining whether results are significant (meaningful) or not take into account the size of the samples being compared.  An apparently big difference in frequencies of a disease between e.g. Port Hope and the rest of Canada could be non-significant, and an apparently small difference could be significant, all depending on the size of the samples from Port Hope and Canada respectively.   And one case more or one case less in a sample can indeed make the difference between significant and non-significant - the techniques are so designed precisely to allow the observer to decide what is meaningful and what is not.

After having heard Ms. Lane make her facile comment on statistical significance, we question whether she is qualified to comment on the work of a recognised expert such as Dr. Mintz.   Because Ms. Lane's comments could leave a totally incorrect impression in the minds of listeners and viewers, we plan to bring her remarks to Dr. Mintz's attention, to give him an opportunity for rebuttal.

5.    Scientific Peer Review

FARE'S Submission pointed out that the author(s) of the "Synthesis Report" had demonstrated a serious and disconcerting misunderstanding of the concept of scientific peer review.  When scientists use the term peer review it is understood to mean that the reviewers are chosen by a third party (a journal editor), without the knowledge or influence of the authors, and known associates or collaborators of the authors are excluded as peer reviewers.

Instead, the CNSC chose its own reviewers, and these included Health Canada scientists who were reviewing the CNSC's review of work by, amongst others, Health Canada scientists.

Two astute Commissioners, Dr. Barnes and Dr. McDill, themselves both distinguished academics, challenged Dr. Thompson with this fact, endorsing FARE's statement that Peer Review implies that reviewers are at “arm's length” from authors.  These Commissioners pointed out that what had been called “Peer Review” in this case was in fact nothing more than “external review,” and by collaborating colleagues at that.

Both Dr. Thompson and Ms. Lane further compromised CNSC's integrity on this issue by obstinately maintaining the correctness of the claim that the Report had been “peer reviewed,” even though the reviewers had been selected by the author(s) and included Health Canada employees reviewing comments on Health Canada studies.


6. The “Healthy Worker Effect.”

FARE's Submission pointed out that the "Synthesis Report" mentions two studies on former workers at Eldorado (now Cameco), and that these studies found that the “only cancer death, which showed statistically significant excess, was cancer of the rectum, based on 7 deaths.”  However, this result is quite different to that reported in the study (designated RSP-0205) from the same series, on Eldorado workers, listed in the Port Hope Mayor's so-called “peer review studies,” which found statistically highly significant levels of lung cancer.  We commented that it is most curious that this article, which is in the same series of studies on former Eldorado workers as others mentioned in the “Synthesis Report”, is not mentioned in this Report.   Similarly, a “Health Canada Fact Sheet,” in referring to RSP-0205, erroneously stated that this study showed that “there was no significant relationship between occupational exposure and cancer incidence, cancer mortality or other causes of death.”

At the meeting on April 29, Ms. Lane repeated the claim that studies on Eldorado workers had found no problems and she added, as also stated in the "Synthesis Report", that Eldorado workers were found to be as healthy as members of the general public.  In stating this, Ms. Lane has inadvertently drawn attention to an apparent flaw in the studies she was citing.

Epidemiologist Ms. Lane and CNSC appear to be unaware of what is known, in the scientific and specifically the epidemiological literature, as “The Healthy Worker Effect”.  This term was coined by the Australian researcher Anthony McMichael (see e.g. McMichael, 1976).  Workers in hazardous occupations as in the Nuclear Industry are highly selected on the basis of being in good health to start with.  In epidemiological studies of people exposed to health hazards such as radioactivity, the cohort of exposed people should be compared to a “control” cohort of non-exposed individuals who are not only matched in all other respects, including age, sex etc. but who are also selected for being “healthy.”  The latter has been historically ignored in studies on nuclear industry workers, with the result that the harmful effects are often masked, because the workers, being healthier to start with, withstand the onslaught of radiation better than average people would.  This fact makes the previously reported occurrence of lung cancer and other diseases in former Eldorado workers far more significant than previously suspected.

It is shocking that CNSC appears to be unaware of this fact, is unaware of previous studies on Eldorado workers that show increased incidence of lung cancer, and is willing to uncritically accept a “Synthesis Report” that brushes the data aside.

Besides those scientific points, we would like to draw your attention to two examples of questionable procedure.

1. On two separate occasions, Ms. Lane appeared to be reading out prepared answers to supposedly impromptu questions from commissioners.

On the webcam she appeared to be reading verbatim answers to questions asked by yourself on the Mintz report, and by Dr. McDill on peer review. We would like your explanation for this, because it has the potential to shake public faith in the integrity of the hearing/meeting process, and raises questions about your own role, Mr. Binder, as both CEO of the staff (their boss) and chairman of the commission (supposedly conducting a hearing in the interest of public safety). We cannot imagine anything more hurtful to the credibility of the CNSC than this visual evidence that your hearings and meetings may be staged in advance.

2. Commissioner Harvey asked Dr. Thompson why the "Synthesis Report" was translated and put on the Commission’s website before it came before the Commission and underwent public scrutiny.

He did not get an adequate answer to his question, other than that staff did what they understood they were asked to do. This makes it incumbent on the Commissioners to make explicit and public their decision on the staff’s two main recommendations – that the "Synthesis Report" is now a “primary reference” for health effects in Port Hope, and that no new health studies are needed here, despite the fact that our community is supposed to be about to host the largest clean-up of radioactive waste in Canadian history. (Dr. Patsy Thompson’s assurance that health effects will be tracked “indirectly” by environmental monitoring was not adequate, since the Environmental Assessment for the low-level clean-up has already stated that there are not likely to be any adverse health effects.)

But there is an even more fundamental reason to question the Commission’s procedure for dealing with this Report. Asked by Commissioner McDill if the Report is final or will staff amend it, Dr. Patsy Thompson said “the intent is that the Report will stand as a final report” (though suggestions from CNSC Staff could be taken into consideration).  Since it was posted on the CNSC website on April 15, well before public comment from F.A.R.E. and the Port Hope Community Health Concerns Committee was received, that means your public consultation on the Report was a sham, and it would appear that the intention has been that none of the concerns raised in our interventions – some of which seemed to be supported by one or more commissioners – would be taken into account.

We absolutely demand your explanation for this, sir, as well as to the other points raised in this letter.   In light of the large number of scientific and procedural flaws in the "Synthesis Report" and its release on 29 April, 2009, we respectfully suggest that it is absolutely imperative that this Report be completely revised, to take into account the issues we have raised.  Most importantly it must be acknowledged publicly that there is no scientific evidence that Port Hope is safe, and that there is a serious unsolved problem of radioactive contamination.

Sincerely,

Louise Barraclough
Interim President
Families Against Radiation Exposure


C.c.    All CNSC Commissioners
       Mayor of Port Hope
       All Port Hope Councillors
       Federal Minister of Natural Resources

       Federal Minister of Health
       Ontario Minister of Health
       Ontario Minister of the Environment
       Northumberland Today
       Northumberland News
       Medical Officer of Health
       President, Council of Canadians
       Waterkeepers
       President, Canadian Medical Association
       President, Ontario Medical Association


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Mankuso T, Stewart A, Kneale G (1977) Hanford I: Radiation exposures of Hanford workers dying from cancer and other causes.  Health Physics 33, 369-384.

McMichael, AJ. (1976) Standardized mortality ratios and the "Healthy Worker Effect": Scratching beneath the surface. Journal of Occupational Medicine 18, 165-168

Muller HJ (1939) Report of investigation with radium.  Medical Research Council Special Report Series no. 236 (London, 1939).

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United Nations Scientific Council on the Effects of Atomic Radiation www.Righthealth.com/topic/united_nations_scientific_council_on_the_effects_of_atomic_radiation.

United States National Research Council: www.Righthealth.com/topic/united_states_national_research_council.

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