Wednesday, August 17, 2011


IICPH Response to OPA Report,by Marion Odell ( ),.February 28, 2006
Hon. Dalton McGuinty, Premier,Rm 281 Main Legislative Building,Toronto ON M7A 1A4
Re: IICPH Response to the Ontario Power Authority Proposal

Dear Mr. Prime Minister, McGuinty,
I am writing to express the concern of the Institute of Public Health, for the lack of due consideration of
the health effects of the continued reliance on nuclear power electricity generation as
delineated in the Ontario Power Authority's Integrated Power Supply Plan.
We have a very deep concern with the process whereby the government is making its
decisions so far. Without a full exploration of the health effects from nuclear waste and,
particularly, particulate radiation from nuclear reactors, I fear that the true hazards to
health will not be disclosed. I attended the consultation held in Toronto on the evening
of February 15th, which amply demonstrated to me and to others who attended that the
process was flawed.
Having now received the brochure, "Our Energy, Our Future " in the mail, there is no
doubt that only an inquiry by an independent impartial person such as a judge, where
expert witnesses would be called to give evidence concerning the health safety of
nuclear power plants, will suffice. Otherwise, the interests of Ontarians and others
downwind and downstream will not be served. The bias toward the messages
espoused by the proponents of nuclear generation of electricity is simply too evident.
From accounts I received, very little was discussed about the health effects of
particulate radiation from nuclear power plants. Indeed, there was no opportunity to
refute the statements put forth by a proponent for nuclear as those of us who could
have done so were cut off without a chance to speak by the moderator.
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Setting aside the immense cost of nuclear power plants, their vulnerability to nuclear
accidents, earthquake damage, (Pickering sits on the side of Frenchman's Bay near
two fault lines), terrorist attacks, their need for shutdowns for expensive repairs, the fact
that they leak radioactivity into our environment and as they age, this leakage
increases, setting that all that aside, what is the big problem?
Pickering and Darlington power plants are very close to huge populations, the Greater
Toronto Area, the Golden Horseshoe and some of the most precious farmlands in the
province. What devastation there would be if we had a nuclear accident in this most
important area, not only to the people themselves, but to the whole economy of the
country! Although our nuclear power plants have a good reputation for safety, there are
acts of nature that can cause problems, which if not responded to properly can lead to
a nuclear accident. These include such things as earthquakes, thunderstorms, floods
and unusual wind conditions Human error can play an important role in meltdowns.
There is also the danger of terrorist attacks. Setting all that aside, the most serious
threat is that of nuclear waste. From the mining, smelting, refining and manufacture of
fuel rods to the actual production of electricity, nuclear waste is produced.
Nuclear Power Plants produce dangerous nuclear waste. They emit radioactive
substances into the air and water, in small amounts, but frequently. The solid waste,
used fuel rods, contaminated equipment, protective clothing, etc., the plant itself, when
finally decommissioned, provide a problem for which there is no suitable secure longterm
means of disposal. An organization set up to find a solution, the Nuclear Waste
Management Organization (NWMO), wrestled with this problem. Their
recommendations did not, in our opinion, produce a safe solution. There is none!
Nuclear waste has long been the Achilles heel of the nuclear industry.
Radioactive emissions into air and water at low levels are frequent from nuclear
power plants. These are most troubling because they add to the nuclear radiation that
is already present in our soil, air and water (1). This comes from radiation that occurs
naturally to all the so-called "background radiation", residuals from the atomic bomb,
testing of bombs, nuclear accidents, the mining, refining and transportation of uranium,
the use of radioactive weapons such as depleted uranium, and from the myriads of
nuclear power plants around the world. In the U.S. and I believe, in Canada too, the
radiation emitted from a nuclear power plant in one year is considered "background
radiation" the following year. This is a shell game. It sounds so benign that those
lacking knowledge of the nature of ionizing radiation might think it is gone. Of course, it
is not really gone, just minutely degraded depending on the half-life of the particular
radioisotopes involved. Particulate radiation will remain radioactive depending on the
radioisotope from which it is derived. Some half-lives are exceedingly long.
CANDU (heavy water reactors) used in Ontario's nuclear power plants emit tritium
into the air in puffs of steam from their stacks and into surface water on a regular basis.
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CANDUs emit more than 100 times the tritium released from other reactor designs and
also 40 times more Cesium-141. See the report of the Standing Parliamentary
Committee on Forestry, Energy and Environment called "The Eleventh Hour" released
in January 1988.
Tritium (H-3) is a radioisotope of hydrogen with two neutrons. The rest of the atomic
weight comes from one proton. It has a half-life of 12.5 years. It is emitted from a
nuclear power plant in the white puffs of steam from its stacks and in water discharged
into surface water. Tritium, as a chemical, combines with oxygen just like ordinary nonradioactive
hydrogen, forming tritiated water, HTO. It is of concern because it goes
wherever water goes whether gaseous, surface or ground water. Tritiated water will go
a long way from its source. It is rapidly transported and can travel for long distances. It
easily binds with organic molecules and can concentrate in the DNA (2).
Since most of the human body is made up of water, this is a very great concern. Of the
tritium you inhale or ingest, 90 % leaves the body quickly, whereas 10% can become
joined to organic molecules including proteins and to DNA itself. So here and there
these atoms of tritium are radiating in the human body. Every living thing in our
biosphere is dependent on water. People who live near nuclear power plants are
receiving tritium in the air they breathe and from drinking water on a regular basis.
Since children breathe in proportionally more, they are generally more seriously
affected. They also play in the dirt. Anyone who eats produce or drinks milk from areas
where soil is contaminated by tritium will receive tritium into their bodies. Guess who
drinks a lot of milk? Children, babies and nursing mothers do.
Measuring comparative levels of tritium in water is becoming more difficult as more
areas are contaminated. For instance, in the Screening Report of 2002, the tritium
levels taken from 15 water supply plants in communities across Ontario were used as
background controls for the water specimens used to measure tritium levels from the
effluent from nuclear power plants. Since tritium can travel a long way from its source,
some of the control areas could very well have been within the groundwater/surface
water areas affected by the nuclear power plants. Therefore, their estimates of
"background" would not be accurate.
Regulations and Standards For the most part, the nuclear industry takes direction for
allowable emissions from nuclear power plants from the International Commission on
Radiation Protection (ICRP). These standards are not health based, but rather, a
risk/benefit trade-off. The regulations for the industry are based on cancer deaths and
not on the other myriad health effects of low-level radiation, which include teratogenic
and genetic effects and autoimmune diseases. Dr. Bertell believes that it is clear from
study of the atomic bomb research that focusing on fatal cancers was a research
simplification, chosen for simplicity of calculation, and it was not meant to claim that the
only health effects from exposure to radiation were cancers (3).
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There is also serious discussion among radiobiologists about the inadequacy of the
ICRP model for dose and dose-response, based on the physics model. There is
growing agreement that it is inappropriate for application to internal alpha emitters (4).
Both NATO and the Institut de Radioprotection et de Sureté Nucléaire (IRSN) (5), the
French Official Radiation Protection Association, have found the ICRP methodology to
be faulty. The Report of the European Committee for Radiation Risk (ECRR)
presents a more up-to-date model for calculating health risks. Unlike the ICRP, the
ECRR uses evidence from the more recent research and new discoveries in radiation
biology and human epidemiology, to create a system of calculation which gives results
that are in agreement both with the mechanism of radiation action at the level of the
living cell and observation of disease in exposed populations.
The ECRR considers the present risk model of the ICRP essentially flawed. "The
Committee concludes that the ICRP justifications are based on outmoded philosophical
reasoning, specifically the averaging cost-benefit calculation of utilitarianism." Dr.
Rosalie Bertell in her article "Can the ICRP be Trusted to Set Radiation Standards?"
states, "The regulations are not a demarcation between safe and unsafe. They are just
an arbitrary decision as to how much the public should be willing to tolerate for the
benefit of the activity" (6).
As early as the 1950s and 60s, some physicists and other scientists were looking at the
possible connections to radiation of mutations and autoimmune diseases. The
following quote is taken from Chapter 11 of Principles of Radiation Protection, a
textbook written for Health Physicists edited by Karl Z. Morgan (7), and J.E. Turner
published by John Wiley & Sons, New York, 1961. It is taken from Chapter 11 Section
11-7 written by P.R.J. Burch, formerly of the Dept. of Medical Physics, University of
Leeds, U. K. The quote in turn references himself and R.G. Burwell in the Quality
Review of Biology, Vol.40, p. 252, 1965.
"If radiation is capable of inducing the same type of mutation as that which occurs
spontaneously, then the problem of assessing the effects of radiation on initiation of
autoimmune diseases is entirely analogous to the problem of radiation carcinogenesis
described in Section 11-6. ... Nevertheless, it seems quite likely that rather similar
spontaneous and radiation mutational mechanisms (spontaneous and induced DNA
strand switching) are implicated in the pathogenesis of both autoimmune and malignant
conditions" (7).
The official NATO report was dated August 1992, and was submitted to the Defence
Ministry in Paris on June 29, 2005.
The Hormesis Theory Consideration of the health effects of nuclear power generation
in the industry appears to be influenced by the Hormesis Theory, which advances the
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opinion that low dose exposure to ionizing radiation induces "beneficial" effects. Dr.
Bertell, in the above noted document, (Ref. 3) page 16, states, "Claims of low dose
hormesis have frequently been based on high dose observations, and the only
mechanisms offered for these effects has been speculation on repair overshoot at the
cellular and genome level. Cell growth as hormetic is the most troubling claim, since
illicit growth stimulation signifies catastrophe to biological organisms ... In order to
produce one "good" effect, one must endure many other unwanted "bad" effects which
will in the long run claim a physiological price perhaps significant, although they evolve
to a clinically observable level more slowly."
Some scientific discoveries that support the presence of health effects at lowdose
In the 1960s, women were sometimes given abdominal x-rays in the first trimester of
pregnancy. There was anecdotal evidence of an increase in leukemia in the children of
these mothers. Dr. Alice Stewart of the UK conducted a pioneering study that showed
that a single x-ray in the first trimester increased the chance of childhood leukemia by
50%. Alice Stewart published her first paper in 1955, before there was a nuclear
industry. These findings were attacked by medical doctors and radiologist and also by
the nuclear physicists who were "managing" the nuclear weapons. Her results have
been amply confirmed by the medical data since then (8).
In 1972, Dr. Abram Petkau, a Canadian physician and biophysicist at the Atomic
Energy of Canada Ltd. Whiteshell Nuclear Research Establishment, completely
overturned all conventional ideas on the biological damage produced by extremely low
doses of radiation. This was first published in the March 1972 edition of HEALTH
PHYSICS in an article called, Effect of Na-22 on a Phospholipid Membrane. He
reported that cell membranes which could withstand radiation doses as large as tens of
thousands of rads when exposed to a short burst of X-rays without breaking, ruptured
at less than one rad when subjected to low intensity protracted radiation such as that
produced by radioactive chemicals. This finding was completely contrary to all previous
observations. This is termed the Petkau Effect. Subsequent investigations by Petkau
and their co-workers showed that the cell membrane damage was due to a completely
different biological mechanism than the direct hit on the DNA in the nucleus of the cells
that had been observed at the high dose.
In his book, The Petkau Effect (9), Ralph Graeub states,
"Over a period of time, such as chronic exposures from inhaled or ingested
radioactive materials can be hundreds of thousands of times more effective in
destroying cell membranes than the same doses given in a short time as in the
case of diagnostic x-rays."
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This important discovery sparked subsequent activities by a good number of
other researchers but was ignored by regulatory agencies.
In his foreword to the second edition of The Petkau Effect, Ralph Graeub of Germany
"Almost twenty years ago when I published the book The Gentle Killers: Nuclear
Power Stations Unmasked", the nuclear establishment contemptuously branded
me as a lone wolf in the wilderness. Since then, the wilderness has fortunately
become much more populated, thanks to the many concerned scientists that have
joined the battle against the threat of nuclear power all over the world, mobilized
first by the Three Mile Island accident in 1979 and then the Chernobyl disaster in
1986. Today, one survey after another indicates that there has been a complete
turnaround in public opinion, so that both in the United States and other countries,
those opposed to nuclear power have become a significant majority".
Physicist, Dr. Ernest J. Sternglass (10) wrote an article on his research on low-level
radiation about the increased incidence of leukemia from fallout that was published in
SCIENCE in 1963. The Atomic Energy Commission dismissed his findings stating that
his statistics weren't good enough. The statistics he used came from the U.S. Bureau of
Vital Statistics. At the time he was director of the Department of Radiological Physics at
the University of Pittsburgh Medical School. Hardly what you would call a "kook" but
some did call him just that according to Leslie Freeman's book, Nuclear Witnesses:
Insiders Speak Out.
Karl Z. Morgan, known as the father of health physics, wrote for and edited a textbook,
Principles of Radiation Protection, published by John Wiley & Sons, New York, in 1967.
He looked at such questions as the ratio of alpha to gamma radiation dose in terms of
the relative biological effectiveness (RBE) as the dose moves toward zero (low dose
range). It states the damage to the cells (RBE) tends to a maximum as the dose
becomes smaller in the low ranges. Thus there is more damage to cells at the lower
doses of radiation than expected. There is more survivable damage to cells from alpha
particles at the lower doses of alpha radiation. That is, the cells are not destroyed, but
are damaged. Uranium, radium and thorium are alpha particle emitters
In Chapter 11 of Morgan's text, he discusses not only carcinogenesis and leukogenesis
but also the large number of other forms of disease (morbidity) and life-shortening
effects based on American radiologists and Hiroshima and Nagasaki survivors. He
notes increases in certain non-malignant diseases, the most important group being the
degenerative diseases of the cardiovascular and renal systems. "The actual surplus of
deaths among the United States radiologists is higher in the cardiovascular-renal group
than in the cancer group" (11) and (12).
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Other effects, premature aging (13), alpha particles affecting the immune system (14),
heredity (genetic effects) (15) are shown in the references below. There are many more
studies, a selection of which you can find in the accompanying references.
Most Recent Corroborative Evidence: the Extended Techa River Cohort (ETRC)
From 1949 to 1956, the rural villagers who lived along the Techa River in Russia were
subjected to both internal and external low-level radiation from a spill into the river from
a plutonium production complex upstream from their villages. Their exposure mainly
came from consuming water, milk and local food products.
Although some work was done earlier to look at the health effects of those involved, the
most comprehensive work has been done in the past ten years. The results of the
study of almost 30,000 people born before 1950 who lived near the river some time
between 1950 and 1960 provide strong evidence of the correlation between low-level
exposure and cancer (16).
Chernobyl Disaster Revisited In September 2005, the WHO, IAEA and UNDP made
a joint press release called "The Heritage of Chernobyl: medical, ecological, social and
economic consequences" which tried to demonstrate that the health consequences of
the Chernobyl accident had been exaggerated. This prompted a stern response from
the governments of Russia, Ukraine and Belorus. In their press release in repudiation
of the WHO/IAEA/UNDP report, they stated,
"This cynical profanation of the consequences of the biggest technogenic disaster
in the history is a sacrilege towards numerous Chernobyl victims; it pushes a new
round of pro-nuclear propaganda aimed by the restoration of NPP (nuclear power
plant) construction programs. This is the main reason why nuclear industry wishes
the whole world to forget Chernobyl."
It states that the report "openly ignores, tendentiously interprets, and even sometimes
falsifies the results of the research of thousands of specialists from the Ukraine,
Belarus and Russia ... it dissembles the data on the impact of Chernobyl to the
countries beyond former USSR borders."
Dr. Bertell has written a critique of the WHO/IAEA/UNDP press release where she
disputes the "science of the findings" (17).
There are a plethora of other important studies. I am mentioning only a few:
1. Radiation Risk to low fluences of Alpha particles may be greater than we thought,
(18), Centre for Radiological Research, College of Physicians and Surgeons and
Environmental Health Sciences, School of Public Health of Columbia University;
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2. Confirmation that Ionizing Radiation can Induce Genomic Instability: What is
Genomic Instability, and Why Is It So Important, (19), John Gofman, M.D., Ph.D. and
Egan O'Connor, Committee for Nuclear Responsibility;
3. How Many Bystander Effects Are There? (20), by Eric J. Hall and Stephen A.
Mitchell, Columbia University
The genetic inheritance from the present use of nuclear power plants already exists
and will soon become manifest as it increases with each generation.
l I think it is abundantly clear that low levels of ionizing radiation are not benign or
beneficial. It is clear from the huge amount of scientifically based peer-reviewed
information already available. More and more proof of the deleterious effects of
low level ionizing radiation will come to light in the months and years ahead as
those who have been affected become ill or pass on their damaged genes onto
the next generation.
l The health hazards produced from the use of nuclear power to boil water to
produce electricity, if fully understood by the general public from the outset, would
have led to the rejection of the use of nuclear electricity power plants.
Unfortunately, that did not happen.
l The mounting evidence of the health effects of low-level ionizing radiation calls out
for a change in direction away from the use of nuclear power generation.
l The Institute strongly urges the government to call a properly constituted
independent inquiry of the type suggested above before making any decision
about continuing to use nuclear power for generation of electricity or for any other
As a people, it is time for us to look at the evidence with a dispassionate eye not
blinded by the mantle of authority of the entrenched interests. The present format
consists of day-long open houses followed by evening public input sessions. There is
no way such a format can result in meaningful discussion of the concerns with the OPA
report. The Canadian public are tired of these "public inquiries" that mean nothing. Only
an open, public inquiry with a specific mandate with specific terms of reference to hear
and take into account the views of a broad spectrum of experts and concerned citizens,
presided over by a judge such as in the case of the Walkerton Inquiry, can satisfy the
imperatives of our democratic right to full disclosure.
There is an alternative, and it is feasible. There is no need to build nuclear power
plants or lengthy transmission lines! Alternative renewable environmentally benign
sources along with conservation can result in less ionizing radiation being added to
what has already been produced. Developing renewable energy resources throughout
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Ontario would lead to a cleaner environment for all. The leadership provided by
Germany, Spain and Denmark should be an example. They have demonstrated the
important role that government can play to bring about a strong renewable energy
system. More and more of the public are becoming aware of the health effects of not
only coal-fired plants, but also of nuclear power plants. In spite of the advertisements of
the Canadian Nuclear Association to promote "NUCLEAR" as "CLEAN", more and
more people are coming to understand the dangers of low-level ionizing radiation.
The IICPH recommends that the present Ontario government move to phase out the
use of nuclear power to generate electricity and move to renewable energy sources as
soon as possible The current policies intended to support renewable energy should be
greatly magnified. It takes political will at the provincial and federal level to achieve the
rates of adoption of renewable energy that are possible and necessary in Ontario. The
Province of Ontario could be the vehicle for bringing about the necessary change in
direction. It would not be long until the benefits would accrue towards a cleaner
environment. You would have the satisfaction of setting a trend that other jurisdictions
could follow.
If we love our children and grandchildren, if we recognize that we are stewards of our
biosphere, we must not turn a blind eye to the hazards from nuclear radiation. The
health risks from even very low levels of radiation need to be recognized. No one is
protected from the effects of ionizing radiation. In this 21st century, we are all at risk.
Marion Odell
International Institute for Public Health
cc Hon. Donna Cansfield, Minister of Energy
Hon. George Smitherman, Minister of Health
(1) BEIR 19900 Health Effects of Exposure to Low Levels of Ionizing Radiation: ISBN 0-
309-03995-9 National Academy of Sciences; No Immediate Danger: Prognosis for a
Radioactive Earth by Rosalie Bertell. Available through IICPH
(2) Tritium, Properties, Metabolism, Dosimetry, Carcinogenic, Mutagenic,
Teratogenic and Transmutational Effects of Tritium
(3) No Immediate Danger:
Prognosis for a Radioactive Earth by Rosalie Bertell, Ph.D., G.N.S.H., biometrist and
epidemiologist. Still available through IICPH
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(4) ECRR Recommendations of the European Committee on Radiation Risk, Chris
Busby, ed., Regulator's Edition.
(5) The official NATO report dated August 1992, which was submitted to the Defense
Ministry in Paris on June 29, 2005 and made public by France on July 1, 2005.
(6) ECRR2003 (ISBN 1 897761 24 4) can be obtained from the publisher at a Green
Audit price of EU 75.00. Email to for information. The quote can
be found at Dr. Bertell's article is at
(7) Karl Z. Morgan See other documents in "Human Radiation Studies: Remembering
the Early Years"
(8) Alice Stewart, Low-level Radiation: The Effects, Human and Non-Human,; One Hundred Years After
Roentgen, Proceeds of the International Congress, Berlin, 1995, Low Level Radiation
Exposure Effects in the Tri-State Leukemia Study, Rosalie Bertell, pages 48 - 59,
published 1997.
(9) The Petkau Effect
(10) Ernest J. Sternglass
(11) Radiosensitivity Mechanisms at Low Doses: Inflammatory Responses to
microGray Radiation Levels in Human Blood, G.Vickers, Dept. of Biology, University of
Bremen, Journal, International Perspectives in Public Health, Vol. 9, pp. 4-20 1993.
(12) X-Ray Exposure and Premature Aging, Rosalie Bertell, Roswell Park Memorial
Cancer Institute, Journal of Surgical Oncology, Vol. 9, 379 - 391 1977.
(14) Alpha Particles
(15) Heredity
(16) SCIENCE Vol. 310, 11 November 2005,
(17) Statement of the Russian Political Parties
Rosalie Bertell responds to the 2005 WHO/IAEA/UNDP Press Release on Chernobyl
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Internal Irradiation and Health Consequences of Chernobyl Accident" Chris Busby
(18) Radiation Risk to low fluences of Alpha Particles
(19) 100 Years after Roentgen, Proceeds of the International Congress, Berlin, 1995;
“Low Level Radiation Exposure Effects in the Tri-State Leukemia Study”, Rosalie
Bertell, pp. 48-59, published 1997.
(20) "How Many Bystander Effects Are There?"
From the IICPH Resource Centre
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