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David Long "5
915 Tenth Street P.O. Box 758
Greeley, Co 80632
Dear Mr. David Long,
Our names are Parker Jolly and Maxwell Musgrave. We are currently seniors at Rocky
Mountain High School and will both be graduating in May of this year. We are in American
Government class and have been doing a lot of research on the uranium mine proposal in
Northern Colorado.
We believe that the uranium mine in Northern Colorado would have a very negative impact on
our way of life. We are known for our beautiful scenery and numerous open spaces around our
community. We've come to find that apparently, there will be a"natural reductant" dissolved in
our water to precipitate remaining uranium or metals in the water. I don't know about you, but I
don't want to be drinking water with metal in it. Sure the uranium mines will help bring
alternate energy to the world, but at the same time will be sacrificing the peaceful lives and
beautiful community that people have come to love. We believe this uranium mine will scar the
land, emit harmful radiation into our everyday lives, and will cause negative effects on the land
and the public in the long run. We recently read an article on how Virginia's public
participation, helped persuade the final decision makers' to kill their uranium mining bill. So
many people chose to get educated on the situation, speak their opinions, and put their ideas into
action. We believe that we,Natives to Colorado, can do the same and influence others to learn
more. Being new to the voting community, we feel that it's very important to have our voices
heard, and represent the young voters' opinions in this situation.
We are very against the uranium mining proposal for Northern Colorado because we do not want
to be drinking water with foreign substances in it, having our children and grandchildren exposed
to radiation, and having our beautiful community compromised just to have a few more job
openings. Please consider this letter in your decision, and know that we are representing the
younger voters in Northern Colorado. Thank you for your time and consideration.
Sincerely,A (\A" r vcyr "c-vzz
Maxwell C. Musgrave Parker A. Jolly
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Fort Collins, Colorado, 80526
Monday, March 3`d, 2008
Dear Commissioner Bill Garcia;
Recently our government class has been researching an issue that has bothered not
only our school but the whole community, Uranium Mining. This letter is to find out
where you stand with this topic on whether you stand against it or you're for the
mining of uranium. We at Rocky would love your input on this issue it would give us
not only a since of pride but a good idea on where are commissioners stand on this
issue.
Our government class, as I've said before has done a lot of research on this topic,
and found out that this uranium mining sounds like a bad idea. Scientist say uranium
ore in our bodies are among the deadliest mineral deposits on the earth. Not only does
it do that but water, sub surface and surface, air quality, Residents (health and
welfare), property values, livestock, and wildlife are all severely being threatened by
other uranium mines and it would be a big risk to ruin all of that for a bit more
nuclear power. Although not much waste is produced, it is very, very dangerous.
It must be sealed up and buried for many years to allow the radioactivity to die away.
Nuclear power is reliable, but a lot of money has to be spent on safety - if it does
go wrong, a nuclear accident can be a major disaster. People are increasingly
concerned about this - in the 1990's nuclear power was the fastest-growing source of
power in much of the world. In 2005 it was the second slowest-growing.
We are Rocky Mountain would love your input and thank your for taking your
time to read this letter. You are the final decision on this topic. My personal input is
that you vote against it and realize that this is not a good idea and may ruin the
community with only single flaw. It is amazingly risky and I would say better safe
then sorry. Thank you for your time and it would be an honor if you wrote back.
Yours Sincerely,
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March 12, 2008
Douglas Rademacher
Weld County Commissioners -
915 Tenth Street
P.O. Box 758
Greeley, CO 80632
Dear Weld County Commissioner Douglas Rademacher:
As a citizen of Larimer County, I am writing to express my concern about the purposed Uranium
Mining that Power Tech wants to perform in Weld County. Being a young citizen of 18 years,
there are several things about the Uranium Mining site that concern me.
The proposed location for the Centennial Project site is a concern. It is my understanding that the
proposed site will only be 11 miles North of Fort Collins, a city with a population of more than
129,467 people; 13 miles south of the Colorado/Wyoming border, a region of more than
5,262,671 people; 16 miles northwest of Greeley, a city with a population of more than 89,046
people; and 80 miles north of Denver, a city with a population of more than 566,974 people.
Since the Uranium Mining will be producing radiation, these are very scary numbers for the
number of people who will be potentially affected. Even just for me, it is scary knowing that
there will be lots of radiation in the air and the groundwater that is so close to my home. I would
hope that it also concerns you to know that radiation will be so close to not only your home, but
the homes of our friends and families.
The open-pit mining, that is proposed to be in the southern part of the project, will be closer to
the residents of Denver. Anyone who lives here in the Front Range knows about how the wind
can really blow east of I-25. With an open-pit being in an area with high wind, I am concerned
about the potential of the radiation blowing into the Denver area. As Denver continues to grow,
so will the population. The result will be even more people who could potentially be affected by
radiation. Some of my future career choices would involve me working or living in the Denver
area. Living in an area where I could possibly be affected by radiation is very scary for me. Even
if it doesn't blow directly into the City of Denver, it could still affect the residents if it were to
blow into our sources for water, livestock, or local crops.
Another concern I have about this project is that even though In-Situ Leaching is safer, it still
could affect people and the groundwater. The main affect would be to the groundwater because it
could never be restored to its original condition again. The radiation levels in the groundwater
will only continue to increase. Should that happen, then our plant life could absorb Selenium,
which is found with Uranium. This could result in an increase in loss of livestock that have
grazed on the plant life containing Selenium. Also, cancer and other illnesses could increase in
humans from consumption of the animals or plant life in the region. It may mostly affect
children, seniors, and people with chronic health problems, but still it can increase cancer in
everyone. I don't know about you, but it terrifies me the thought that when I start raising a
family, I could end up with a child that has cancer from the environmental choices that were
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allowed by my local govermnent officials. Even those who do not have children could
potentially be affected. Either by watching a family member, their friends or neighbors, or
themselves suffer with the side affects of the radiation.
If we let Power Tech start to mine for Uranium, then we will be putting ourselves and everyone
we love and care about in danger. Why would we want to do that? Plus, if we agree to let Power
Tech create the Centennial Project, then other mining companies may want to create other
mining sites in this region. From what I have learned, many mining companies will say they will
restore the landscape, but it never looks the same again. Do we want the beautiful state of
Colorado to turn into a mining state? If so let me know because I do not want to live in a place
that accepts replacing beautiful landscaping with all kinds of wells and piles of dirt everywhere.
Nor do I want to live in a place that could be potentially harmful to my health, or the health of
my family,just because I chose to live there.
I hope that you take everything I have told you into consideration when you are making your final
decision on whether or not we should allow Power Tech to start mining here in the beautiful
State of Colorado.
Thank you very much for taking the time to read and consider my concerns as a resident of
Northern Colorado.
Sincerely,
/ /kLk_
Amber Weikum
4231 Table Mountain Place
Fort Collins, Colorado 80526
(970) 223-7960
Bamberbutterlly@yahoo.com
Dear Mr. William Jerke,
It has come to our attention that you will be one of the main decision makers
in whether Power-Tech. will have the ability to mine for urianium in
Colorado. Based on our research we have come to the conclusion that
Power-tech should not have the right to mine for uranium in Colorado
especially in Weld County. Some of Power-techs points are that they will
bring 100 new jobs, thousand of tax dollars to weld county and perhaps
millions of tax dollars to Colorado. Instead of considering their minor
advantages we are asking you to consider the major disadvantages of mining
in Weld County.
First consider the radiation that uranium mining will bring. Uranium will
extremely increase the amount of radiation doses/rems a person will receive
each year. This will also extremely increase people's chances of developing
cancer, radiation sickness, and genetic mutation. Basically if you allow
power-tech to open uranium mines you are endangering our generation and
many generations after ours to sickness and early deaths. Next you need to
consider the waste disposal. Uranium remains radioactive for thousands of
year and requires safe disposal away from society. If and when that waste
evaporates it will put toxins and chemicals into the air. Also transportation
is very risky and if one of the vessels the waste was in were compromised,
the results may be deadly therefore it is not worth the risk. Finally, with
Colorado being conscious of its water use we don't need another source
draining our rivers and irrigation, which will not be recycled or treated.
They plan to use over 10 million gallons of water ever month for their
project, which we won't get back at all.
Therefore we ask of you to deny power tech the resources and ability to
mine uranium in our back yards.
Sincerely,
Autumn O'brien & Mackenzie Wrobbel C 1nu''eS S
7 as& CGl I i nS , 0) uS3(y
it
915 Tenth Street
P.O. Box 758 - E ,'.7 .-7
Greeley, CO 80632
Dear Mr. Bill Garcia:
As seniors of Rocky Mountain High School,we have serious concerns about the
proposed uranium-mining project in Northern Colorado. Texas,Nebraska,and Wyoming
have all allowed uranium mining to take place on their land,but we believe that Colorado
should be the state to draw the line.
Everything we have read about the proposed projects indicates it cannot be done without
significant risks to both local and regional water supplies, as well as posing a hazard to
society. There are too many possible consequences to human health in the vicinity of the
mining. Studies have proven that no amount of uranium radiation is safe for humans. Is
cheaply priced power worth the risk of putting the citizens' health in danger?
Uranium mining is an unnecessary cost and risk to Colorado's land, as well as the health
of its citizens. As the Weld County Commissioner, we believe that you have the power to
stop a potentially disastrous project. Please consider shutting down any future uranium
mining projects in Colorado.
Thank you,
Tara Deeney and Jan Willis
Esther Gesick
From: Esther Gesick
Sent: Thursday, March 27, 2008 4:44 PM
To: 'hgerard987@comcast.net'
Subject: RE: Stop Uranium Mining in Northern Colorado
Attachments: LEUraniumEmail.doc
.EUraniumEmail.doc
(57 KB)
Ms. Gerard,
Please see the attached response.
Esther E. Gesick
Deputy Clerk to the Board
915 10th Street
Greeley, CO 80631
(970)356-4000 X4226
(970)352-0242 (fax)
Original Message
From: William Garcia
Sent: Wednesday, March 26, 2008 4:43 PM
To: Esther Gesick
Subject: FW: Stop Uranium Mining in Northern Colorado
Importance: High
Original Message
From: Gerard [mailto:hgerard987@comcast.net]
Sent: Wednesday, March 26, 2008 4 :33 PM
To: Monica Mika; Trevor Jiricek; Bruce Barker; William Garcia; Bill Jerke; Rob Masden;
Douglas Rademacher; Dave Long; Department of Public Health and Environment; Joe Rice;
Glenn Vaad; Jim Riesberg; Don Marostica; Kevin Lundberg; John Kefalas; Bob Bacon; Steve
Johnson; Scott Renfroe; Bill Ritter; Shawn Mitchell; Randy Eubanks; Glenn Gibson; Kathay
Rennels
Subject: Stop Uranium Mining in Northern Colorado
Importance: High
I have serious concerns about the proposed uranium mining project in
northern Colorado near Nunn. There are no guarantees that the process is
safe for those of us that live so close, and I am not willing to take a
chance with the potential impact on our local and regional water supplies
and the potentially dire consequences to human health.
Residents have invested their futures and the futures of their families
here in northern Colorado. I truly believe uranium mining in northern
Colorado will have awful consequences in the long run. I am asking you to
protect our interests, the human health factor as well as local property
values, by preventing the proposed uranium mining.
We don't need a uranium mine in northern Colorado. As my representative, I
urge you to put a stop to it now.
I thank you for your time and consideration.
Sincerely,
Heidi K. Gerard
842 Durum Street
1
Windsor, Colorado 80550
(970) 686-9440
hgerard987@comcast.net
2
Esther Gesick
From: Esther Gesick
Sent: Thursday, March 27, 2008 8:38 AM
To: Esther Gesick
Subject: FW: uranium mining
Attachments: pat1550834549
POP
CARD_Newsletter_
032508.pdf(15...
Original Message
From: William Garcia
Sent: Wednesday, March 26, 2008 9:12 AM
To: Esther Gesick
Subject: FW: uranium mining
Original Message
From: Robin Davis [mailto:robin@mustanghollow.comi
Sent: Tuesday, March 25, 2008 4 :59 PM
To: Phillip Brewer; William Garcia; Bill Jerke; Trevor Jiricek; Dave Long; Rob Masden;
Douglas Rademacher; paul wood
Subject: uranium mining
I urge you to deny any potential permit applications for any uranium mining within Weld
County.
My real wish is that Weld County would include something in the Master Plan that
eliminates the possibility of any uranium mining taking place.
Water is much too important to our economy and our lives! ! ! !
Please see the news below. This uranium rush is threatening us all.
Robin Davis
1
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C . A . R . D . NEWSLETTER
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CARD. PO Box 143. Wellington. CO 80549. 970.372.0029 (leave message) www.nunnglow.com
Wanted: Locals to Organize Petition Drives
C.A.R.D. supporters going house to house, collecting signatures in their own neighborhood, have
been extremely effective. Many feel it is easier to ask for signatures from people they know. And a
lot of people have appreciated the opportunity to sign! There is no reason why we shouldn't be
able to collect tens of thousands of petitions from neighborhood drives.
Please consider working your own neighborhood. You may print petition forms from the
www.nunnglow.com website. You may also contact us, and we will get the material to you. Be a
uranium mining activist for a day! Your efforts will make a tremendous difference. You can send
the petitions to the CARD address listed above. Petition progress can be checked directly on our
website.
Upcoming Events — Join Us!
March 26, 2008: Longmont Town Meeting
CARD's next public education meeting will be held Wednesday, March 26, in Longmont from 7 PM
to 9 PM. It will be held in the Front Range Meeting Room at the Radisson Hotel & Conference
Center. The Radisson is at 1900 Ken Pratt Blvd in Longmont (on HWY 119 just east of Hover St.).
The Front Range Meeting Room is located behind the hotel at 1850 Industrial Circle.
April 8, 2008: Greeley City Council Meeting at 6:30 PM in the Council Chambers of the Lincoln
Park Annex Building at 919 7th Street. A resolution against uranium mining will be considered.
Legislative Update
House Bill 1161 has passed out of the Appropriations Committee with an 11-2 vote and will now
go to the House floor for a vote, maybe as early as Friday, March 28. This means that there is still
time for you to contact House representatives and ask them to support the bill.
House Bill 1165 is still in the Committee for Agriculture, Livestock and Natural Resources. Testi-
mony is closed on the bill, but the date for the committee vote is not set. Not only is this yet an-
other opportunity to urge the Committee members to support the bill, it is critical that you take the
time to contact them before they vote. See a list of committee members and their contact info at
the end of this newsletter.
This is why it is so important that you give your input: (1) HB 1165 would insure that property own-
ers know when exploration for minerals is planned in their immediate area. Currently, people
across northern Weld County —and the state — have no way of knowing if or when a company
wants to drill for uranium or other minerals in their immediate area.
(2) HB 1165 would also give local governments more of a say when mining is proposed. It asserts
the importance and merits of local control, and introduces balance into the mining permit process.
Local government has the responsibility - and thus must also have the authority - to develop land
use plans that can protect our water resources for our children and our children's children. (3)At
the moment, support for HB 1165 does not seem to be as strong as it is for HB 1161. Your input at
this time can make an enormous difference.
The Denver Post Supports Bill 1161
Excerpts from the Denver Post Editorial, March 20, 2008
...Th(e) surge in demand has sparked renewed interest in Colorado uranium, especially in a new
"in-situ" process...The trick is to be sure that the new mines are monitored to ensure they meet
water standards. And that's where HB 1161 comes in.
"We...have adequate protections in place for the old open-pit mines in the Mined Land Reclama-
tion Act," (Rep.) Fischer told The Post. "Now, it's important to provide adequate protection for
ground water as we deal with this relatively new in-situ technology."
(Rep.) Fischer, an engineer, and (Rep.) Kefalas have worked diligently to craft a balanced bill that
won't ban uranium mining in Colorado but will help ensure that the water supplies vital to agricul-
ture and municipal use aren't sacrificed in a new mining boom. It deserves to become law.
Uranium Mining Opponents Hold Regional Meeting
Ten organizations from five western states met in Casper, Wyoming on Saturday, March 15, 2008
to discuss concerns over uranium mining in their regions and its potential impact to surface and
ground water, human health, and local property values.
C.A.R.D. brought concerns over the uranium mining proposed near Fort Collins. "Of course ura-
nium mining always causes some form of contamination. Water at in situ leach mining sites is not
returned to its original condition," said Jackie Adolph, Outreach Chair. "Most people don't know
that federal policies that subsidize the nuclear industry aren't just about power plants. The nuclear
industry's largest negative impacts have always been in uranium mining and milling processes."
South Dakota faces mining proposals along the southern Black Hills and three groups, Defenders
of the Black Hills, South Dakota Sierra Club and ACTion for the Environment, attended from that
state.
The Powder River Basin Resource Council and the Biodiversity Conservation Alliance attended
from Wyoming with concerns over recent applications for uranium exploratory and mining permits
in the state.
Western Nebraska Resources Council, Nebraskans for Peace, and Nebraska Sierra Club traveled
from northwest Nebraska, where Crow Butte Resources is seeking to expand their uranium mining
operations.
Members of Dakota Resource Council from northwestern North Dakota had concerns over plans
to mine uranium in that state.
The ten groups have issued the following joint statement:
"We want the uranium industry to know that we stand together on this issue. Whether in a
rural setting or a populated area, uranium mining causes radioactive contamination. Past
uranium sites continue to contaminate the air, land, and water. Any bonds designed to pay
for clean-up of former mining areas have not been sufficient, and taxpayers have been
forced to pay the bill. We call on the public and all elected officials to do everything possi-
ble to protect the water, land, and local economies from proposed uranium activities."
Uranium Mill Proposed Near Naturita
...Energy Fuels, Inc. is in the early stages of permitting its Pirion Ridge Mill to process up to 1,000
tons of uranium ore, as well as vanadium, per day. It would be the first uranium processing facility
to be constructed in the United States in 25 years.
The move to build a new facility comes after a recent shutdown of a uranium mill in Canon City,
owned by the Cotter Corporation. That mill closed after a string of violations, complaints and fines.
...Energy Fuels is hosting two informational sessions for the public in Naturita (3-25-08) and in
Montrose (3-26-08).
Radioactive Rush
Will Sands of the Durango Telegraph writes on March 10, 2008 (excerpted) that
...the prospectors, Geiger counters and mining claims have now returned to Southwest Colorado.
The Bureau of Land Management reported 10,730 new filings for uranium mining claims on the
Western Slope in 2007. In 2006, 5,205 claims were filed for the uranium rich region. These num-
bers are up dramatically from the 274 claims filed in 2004.
... courtesy of high prices for the radioactive ore along with a Department of Energy decision last
summer that opens 27,000 acres on the Western Slope to uranium mining. In addition, an energy
company is forging ahead with plans to build a new uranium processing facility in the Four Cor-
ners region.
Colorado mining claims have jumped over 230 percent in the last four years (Source: Environment
Colorado.)
Atomic Minerals Ltd. Identifies CO Uranium Mining Projects
Information posted by the company on atomicminerals.com
Four Colorado uranium mining projects are currently being pursued by Atomic Minerals Ltd. The
Dolores Anticline project is located in the Paradox basin spanning the Dolores and San Miguel
Counties. It consists of 1,177 claims over 24,280 acres, about 30 miles from the Denison Mine
Corporation's White Mesa Mill. The Troublesome Creek project is located in Grand County and
involves 123 claims on 2,400 acres. ISL mining is considered. The Little Wolford project, also in
Grand County, consists of 127 claims on 2,540 acres. The company has filed for a 640 acre state
lease. ISL is considered. The Beaver Creek project in Grand County involves 27 claims on 540
acres, adjacent to the Newmont Exploration project.
Uranium Processor Guilty of Poisoning Birds
Thanks to the Denver Post, March 14, 2008
Denver-based Cotter Corp. has pleaded guilty and was sentenced in federal court for poisoning
migratory birds at its uranium processing facility near Canon City. U.S. District Court Magistrate
Kathleen Tafoya on Wednesday ordered Cotter to pay a $15,000 fine and an additional $15,000
restitution and placed the company on 12 months' probation.
Villagers Protest Uranium Mining at Iditarod Start
Excerpts from an article on KTTU.com (Alaska) posted March 1, 2008
The ceremonial start of the 2008 Iditarod dog sled race provided an opportunity for some
Alaskans to voice their opposition to uranium exploration. Triex Minerals Corporation and
Full Metal Minerals, Ltd. conducted core drilling for uranium about thirty miles from the vil-
lage of Elim last year, near one of the race check points. The companies are gearing up for
continued drilling this summer.
National Treasures Threatened by Uranium Mining
The Grand Canyon is not the only western national monument to be crowded by mining claims.
U.S. Mining Database identifies other areas:
Arches National Park, Utah has 869 claims within 5 miles. 208 of those are made by claimants
with uranium interests (Kee Nez Resources, Robert C Young and Robert P Kirgan.)
Canyonlands National Park, Utah has 233 claims within 5 miles. 218 of those claims are staked
by Kee Nez Resources, which has uranium interests.
Capitol Reef National Park, Utah has 161 claims within 5 miles, of which 14 are made by
companies/individuals with uranium interests (Garfield Resources and Allene O Haws.)
Yellowstone National Park, Idaho, Montana, Wyoming has 21 claims within 5 miles, of which 66
are made by companies/individuals with uranium interests (David W Depuy, Shirley M Depuy,
Donald Floberg, Dorothy R Payne and Robert Payne.)
As for the Grand Canyon, 618 of 815 claims within 5 miles have claimants with uranium interests
(Patrick Hillard, Dir Exploration Inc., Energy Metals Corporation, High Plains Uranium, Inc., Jo-
seph I Cain and IUC Explorations.) A number of other national parks have scores of mining claims
within the same periphery, but none of those are currently uranium-related.
Goliad, TX to Sue Uranium Company over Water Contamination
Excerpts from an article by Tara Bozick in the Victoria Advocate, published March 1, 2008.
...a notice of intent to sue Uranium Energy Corp...went to the company as well as the Texas
Commission on Environmental Quality and the Environmental Protection Agency...The county
plans to sue under the Safe Drinking Water Act in federal court in Victoria.
The notice states that wells in the Evangeline Aquifer were contaminated after the uranium com-
pany began drilling test holes and extracting samples. It continues to state that boreholes weren't
plugged and allowed storm water flowing over land to enter the aquifer.
The lawsuit is part of a larger intent to protect the aquifer...Goliad County Commissioners Court
authorized the suit during its February meeting.
Virginia House Panel Rejects Uranium Study
Excerpts from an article by Anita Kumar in the Washington Post, published March 4, 2008.
...Lawmakers concerned about land, air and drinking water contamination killed a proposal...that
would have allowed a study of whether uranium can be safely mined on 200 acres in south-central
Virginia, eliminating any chance that the controversial bill could pass this year.
After more than an hour of debate, the House Rules Committee defeated a bill that opponents ar-
gued would be the first step toward lifting a 25-year-old state ban on uranium mining.
The decision was a blow to Virginia Uranium, a company that had aggressively lobbied the Gen-
eral Assembly to take the first step toward mining what is thought to be the largest deposit of ura-
nium in the United States.
Meeting Videos on TV
The January 14, 2008, Fort Collins Regional Library District presentation and discussion on the
proposed uranium mining project is available on-demand via the internet. The link is
htto://www.fcgov.com/cablel4 . You can also check out the DVD from the Fort Collins Regional
Library District, www.fcgov.com/library.
We Need Your Donation!
We again thank our contributors for their generosity. We especially would like to thank the people
who keep on donating monthly. This greatly helps us with planning and covering our ongoing ex-
penses. Please join them and help fund operating expenses and lobbying efforts for the 2008 leg-
islation introduced to protect our natural resources, especially our water.
If you're interested in supporting us on a regular basis, $20/month would go a long way towards
our expenses.
You can donate at the www.nunnglow.com website or send your money order or check to CARD,
PO Box 143, Wellington, CO 80549. If for some reason you don't want to be publicly acknowl-
edged for your contribution, please let us know.
Agriculture, Livestock, & Natural Resources Committee
Here is the contact information of the Agriculture, Livestock and Natural Resource Committee
members who are reviewing house bills 1161 and 1165. As stated above, please contact them
and let them know you endorse these important bills.
Frank McNulty
303-866-2936
Jerry Sonnenberg
303-866-3706
jerry.sonnenberg5state.co.us
Wes McKinley
303-866-2398
wes.mckinlev.house@state.co.us
Christine Scanlan
Capitol Phone: (303)866-2952
E-Mail:christine.scanlan.house(a�state.co.us
Mary Hodge
Cap: 303-866-2912
E-mail: mary.hodge.house@state.co.us
Kathleen Curry (Chair)
Cap: 303-866-2945
E-mail: kathleencurrvamontrose.net
Rafael Gallegos
Cap: 303-866-2916
E-mail: rafael.gallegos.house@state.co.us
Buffie McFadyen
Cap: 303-866-2905
E-mail: McFadyen2002@hotmail.com
Marsha Looper
Capitol Phone: (303)866-2946
E-Mail: marsha.looper.house@state.co.us
Judy Solano
Capitol Phone: 303-866-2918
E-mail: judy.solano.housestate.co.us
Randy Fischer
Capitol Phone: (303)866-2917
E-Mail: randy.fischerhouseestate.co.us
Ray Rose
Cap: 303-866-2955
E-mail: ray.rose.housela'state.co.us
Cory Gardner
Cap: 303-866-2906
E-mail: cory.gardner.house@state.co.us
Capitol Phone: (303)866-2946
Who Are We?
CARD (Coloradoans Against Resource Destruction) is a diverse collection of citizens concerned
about the health, environmental and economic impacts of uranium-related activity. We are con-
vinced this project will have dire consequences for northern Colorado and set a dangerous prece-
dent. Our goal is to prevent uranium mining in Colorado and protect our valuable resources, espe-
cially our water, for future generations.
The CARD website, www.nunnglow.com, has a wealth of information about the proposed mining,
the processes and the potential impact on our air and water. On our website you can learn what
you can do to stop the proposed uranium mining, sign an online petition and make a donation.
You received this newsletter because you signed up for it. If you wish to unsubscribe, follow this
link.
Esther Gesick
From: Esther Gesick
Sent: Tuesday, March 25, 2008 8:55 AM
To: 'Edquist, Jeff
Subject: RE: Materials for consideration: Uranium Mining in Weld County
Attachments: LEUraniumEmail.doc
EuraniumEmail.doc
(57 KB)
Mr. Edquist,
Please see the attached response.
Esther E. Gesick
Deputy Clerk to the Board
915 10th Street
Greeley, CO 80631
(970) 356-4000 X4226
(970) 352-0242 (fax)
Original Message
From: Edquist, Jeff [mailto:JEFF.EDQUIST@aei.com]
Sent: Tuesday, March 25, 2008 8:49 AM
To: Esther Gesick
Cc: Robin Davis; jbw@frii.com
Subject: Materials for consideration: Uranium Mining in Weld County
Ms. Gesick,
Please file this letter for consideration of the Weld County council.
Reference: http://www.ccnr.org/bcma.html#pub <http://console.mxlogic.com/redir/?
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This warning of Health Danger is issued by:
THE ENVIRONMENTAL HEALTH COMMITTEE OF
THE BRITISH COLUMBIA MEDICAL ASSOCIATION
BCMA REPORT:
SUMMARY OF MAJOR POINTS
URANIUM INDUSTRY:
OCCUPATIONAL EXPOSURES
Delay of hazard recognition and consequent worker non-protection is an unfortunate but
recurring theme in the Canadian regulatory and uranium industry history:
Radon daughter radiation is a health hazard to workers in advanced stages of
exploration, such as in tunnels and shafts, where very high levels of 1.6 working levels
(WL) have been recorded in low grade deposits (1600 times normal background levels) .
Average radon daughter levels in underground mines range from 0.1 WL to about 1
WL (that is, 100 to 1000 times normal background levels) .
• In open-pit mines. the high density of radon (7.8 times heavier than air) and
atmospheric inversion conditions can cause levels of from 2 to 10 WL in moderate to high
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grade ore bodies.
• Workers in open pits with low to moderate grade ore receive 2 to 4 times the
normal lifetime dose of radon daughter radiation during their employment life, under
conditions where there are no inversions.
• In a uranium mill, with low to moderate grade ore, the millers receive from 5 to
14 times the normal background lifetime dose of radon daughter radiation during their 30-
year working lives.
• Uranium millers may receive doses of gamma radiation 1000 times background from
high grade ores.
Although the AECB assumes workers are receiving only a small fraction of the
annual limits, this is not borne out by the facts.
• Despite AECB claims to the contrary, the risks from radiation in uranium mining
far exceed those of a "safe" industry.
• The 4 WLM annual maximum permissible exposure to radon and thoron daughters
should be lowered to less than 1 WLM per year immediately, and serious consideration
should be given to lowering it to 0.4 WLM per year [ a factor of 10 lower than present
permissible levels ] . This would still exceed risks for a safe industry using AECB
criteria.
• The AECB is unfit to regulate uranium mining.
• Canada has lagged many years behind other countries in its collection of cancer
death statistics among uranium miners. It is most unfortunate that there has been such a
long delay in publication of the follow-up study of the Elliot Lake miners.
• Nuclear industry proponents have tended to minimize risk through lack of
knowledge, generalizations, quoting outdated studies, dilution of risk estimates,
unsubstantiated arguments, personal bias, basing conclusions on inadequate studies,
doublethink, and assuming workers cannot absorb the full truth.
• The new ICRP weighting system [ based on the concept of an "effective dose
equivalent" ] , if accepted, will permit much larger doses of radiation at a time when
reports indicate that cancer risk is many times what it was considered to be 22 years ago.
• AECB reliance on the ICRP as a basis for standards is unwise. That body has
become a political and social arbiter rather than a scientific advisory group.
URANIUM INDUSTRY:
PUBLIC EXPOSURES
Uranium tailings will remain radioactive for hundreds of thousands of years, and will
require such expensive long-term surveillance and maintenance by government and the local
citizenry as to make statements about uranium mining providing revenue very misleading:
• Misuse of uranium tailings has led to internal lung doses calculated to be 100
rems per year to the public.
Conservative calculations show that the public near uranium tailings will
receive a 25 percent increase in lifetime radon daughter radiation.
• Uranium tailings will have appreciable radioactivity for more than 100, 000
years.
In Canada we now have approximately 100 million tons of radioactive tailings;
this will eventually increase to about one billion tons by the year 2000.
• There have been many uranium tailings disasters in Australia, Canada and the
United States. even with the most modern "state of the art" tailings dams.
• The present average allowable exposure to the public [ of 0.02 WL of radon
2
exposure ] could result in 200-300 extra cases of lung cancer per 10, 000 people per
lifetime. In light of current knowledge, this might be considered tantamount to allowing
an industrially induced and publicly sanctioned epidemic of cancer.
This present guideline of 0.02 WL must be immediately withdrawn and replaced
with "no exposure (above ambient levels) of any carcinogen permitted to the local
public" .
• Radon contamination of ground water may be a health risk in pincushion drilling
typical of advanced exploration, yet under present AECB regulations, a couple of hundred
drill holes can be made without obtaining a license. AECB admitted to having no scientific
data to show this is safe; the regulation was based on an arbitrary administrative
decision.
Radium-226 [ released from uranium tailings ] is a superb producer of
osteosarcoma ( bone cancer ] .
In 1959 the ICRP recommended a maximum exposure of 3 picocuries per liter
(pCi/l) of [ dissolved ] radium-226 to the public.
• In 1968 Canada allowed a maximum permissible concentration of 100 picocuries per
liter, with an objective of 10 picocuries per liter [ of dissolved radium-226 ] .
• Ontario has retained a maximum permissible concentration of 3 picocuries per
liter [ of dissolved radium-226 ] .
• New "recalculations" of the ICRP recommend relaxing the radium-226 standard to
27 picocuries per liter (9 times the Ontario limit of 3 picocuries per liter) .
[ NOTE: Canada has since authorized this increase in permissible radium levels in drinking
water. ]
• Certain uranium mining companies in Ontario are discharging radium-contaminated
effluents which exceed the standard of 3 picocuries per liter. With the relaxation of the
standard to 27 this will no longer be [ considered as ] a technical or regulatory
problem.
American standards are as usual more stringent than Canada's; in the U.S.A. , [
dissolved ] radium-226 plus radium-228 cannot exceed 5 picocuries per liter.
• A U.S. Public Health Service study shows increased bone cancer in communities
with 4.2 picocuries per liter of [ dissolved ] radium-226 in drinking water, as compared
with communities having only 1 picocurie per liter.
• The concept that a radium-226 limit for the public can be set ten times too high
because the usual radium-226 levels will only be one-tenth of that, is as inane as setting
a speed limit of 200 kilometers per hour in a school zone because most caring people will
only drive at 20 km/hr anyway.
There are no standards for total radium-226 (dissolved and particulate) ; one
wonders if that is because total radium-226 effluents range as high as 168 picocuries per
liter.
REGULATORY FRAMEWORK:
SETTING STANDARDS
The BCMA calls for an Emergency Task Force into tightening the present radiation
standards. Review by the AECB or by its Committees is unacceptable; the Task Force should
be under the Advisory Council on Occupational Health and Safety or the Science Council of
Canada:
• Industry and regulatory officials are overly eager to select conversion factors
for dose calculations that are at the lower end of the spectrum of values proposed. This
consequently leads to lower risk estimates of radiation effects. The fact that the
calculations are subject to "large unquantifiable uncertainty" leaves one with little
confidence in the conclusions of health risks made by nuclear physicists and former
employees of Atomic Energy of Canada Limited, now associated with the Atomic Energy
3
Control Board.
Canadian regulations lag far behind countries which are more conscious and
concerned about occupational and public health and safety.
• Canadians cannot continue to allow vested interest Ministries and regulatory
bodies to promulgate maximum permissible exposure levels [ of radiation ] .
• The BCMA is on record as calling for a national enquiry into nuclear energy in
Canada, [ including ] a total reassessment of the structure and function of the AECB;
this resolution arose out of our investigations of nuclear waste management and uranium
mining.
• That the AECB consistently and seriously neglected its statutory responsibility
for the regulation of uranium mines is obvious to the most casual observer.
• We believe that the continued use of the ALARA principle, [ unenforced ]
guidelines, and the encouragement of industrial self-regulation is a combination of
objectives that will [ continue to ] compromise the effectiveness of the AECB as a
regulator of uranium mining.
EXCERPTS FROM THE TEXT
OF THE BCMA REPORT
LUNG CANCER AMONG UNDERGROUND MINERS
Dr. Wagoner well described the discovery of the relationship between lung cancer and radon
daughters:
"The real nature of this pulmonary disorder among miners of the Schneeberg (Germany) area
was not identified until 1879 when Harting and Hesse first diagnosed it.
"In 1913, Ainstein reported that of 665 Schneeberg miners dying during 1875-1912, 40
percent (or 276) died of lung cancer.
"Pircham and Sikl, in 1932, reported that of 17 deaths observed during 1929-1930 among
miners of uranium-bearing ores in Joachimsthal (Czechoslovakia) , 53 percent (or 9) were
due to cancer of the lung.
"These same investigators . . . concluded that the most probable cause of these tumors was
radiation in the air of the mines. These investigators also made note 'the miners
themselves state that discovery of a rich uranium vein is always followed some years later
by a strongly increased mortality among them' . "
Hollywood, in his article on "The Epidemiology of Lung Cancer Among Workers Exposed to
Radon and Radon Daughters" in May, 1979, noted:
"By 1940, then, excess deaths from lung cancer among two groups of European miners had
been associated with relatively high concentrations of radon in the mine atmosphere. In
that same year . . . conclusions were drawn that prolonged breathing of air containing a
high concentration of radon, may have caused what was estimated at that time to be a 30-
fold increase in the incidence of lung cancer.
"The percentage of miners developing carcinoma of the lungs in Schneeberg was 63 percent,
in Joachimsthal 42 percent, and in St. Lawrence [Newfoundland] 36 percent. "
Studies in the U.S. were undertaken in the 1950's on uranium miners in the Colorado
Plateau area. These results began to appear in the early 60's, and they showed an increase
in lung cancer with an increase in exposure to radon daughters. Dr. Wagoner noted that
these studies had to be extended and refined to rule out any possible other agent:
"First there was a basic denial that there was such a problem. Then there was a position
that it had to be due to smoking. Then it was on the basis -- well, it had to be due to
4
hard rock mining. There were sequential analyses undertaken to address all of these, what
in statistical terms I would call confounding factors, but in public health terms I would
call delaying [factors] .
"In 1967, Lunden demonstrated that during the period 1950 through June 1965, white
underground uranium miners experienced 37 deaths due to lung cancer whereas only 7.3 would
have been expected [and] through September 1967, 62 deaths due to lung cancer as
contrasted to only 10.02 expected. "
[As noted by Dr. Wagoner, referring to the Colorado data] , observed versus expected
carcinoma of the lung cases in 1978 was 205 versus 40, with an attributable risk of 164
men
"who have died due to lung cancer over and above what I would expect in that population if
they had not been subjected to those exposures. I would consider that as epidemic. "
With the long latent period of carcinoma induction by low level radiation, these numbers
will increase further over the next 20 years.
The submission of Dr. Wigle relating to the St. Lawrence (Newfoundland) fluorspar miners
who were exposed to elevated levels of radon daughters demonstrated an observed incidence
of lung cancer of 65 versus an expected 6.41, with an average ratio of observed to
expected of 10.1 . Dr. Radford noted that the ongoing studies, such as the one of the
Newfoundland fluorspar miners,
"clearly indicate the seriousness of this problem, still with us fifty years after the
risk was originally identified in the Bohemian miners of central Europe. "
The collection of the Canadian [uranium mining] data began in 1974. The Royal
Commission on Health and Safety in Mines in Ontario [the Ham Commission] commissioned
an epidemiological study of the uranium miners in the Elliot Lake area; this was conducted
from 1975 to 1976. Dr. Muller noted that
"The Ontario uranium mining population is characterized by relatively low exposures and
relatively short periods of exposure. There is, therefore, less extrapolation involved
from high to low doses and dose rates, . . . relatively short periods of exposure in most
men, . . . and nearly 20 years of observation time. "
The Ham Commission analyzed the data [81 observed lung cancer deaths versus 45.08
expected] in order to determine whether radon daughters were the agent:
"The lung cancer cases tended to accumulate more in the higher exposure groups, which
indicates that lung cancer risk was greater in the higher exposure groups than in the
lower ones. "
In his analysis of the Ontario data, Ellett stated:
"From the occupational health point of view, it is certain that exposure to radon
daughters leads to an increased risk of lung cancer for the working force as a whole, and
that this risk extends to levels of exposure that are below current occupational
guidelines. "
According to the United Steelworkers of America, the number of lung cancer cases should
now read well in excess of 100 at Elliot Lake and are "climbing steadily" .
MORE EVIDENCE ON LUNG CANCER AND RADON GAS
Dr. Axelson, in his submission on Swedish Miner Lung Carcinoma, stated:
"Several studies have shown an increased lung cancer mortality among Swedish metal
[zinc-lead-iron] miners as probably caused by the exposure to radon and radon daughters
in the mine atmosphere. In a nation-wide survey, as yet unpublished, the average lung
cancer mortality among Swedish miners was found to be about fivefold the normal.
5
"These Swedish studies deal with a life-time follow-up of miners, whereas most other
mining populations have been studied by means of cohorts with a follow-up time of not less
than about 2S-30 years or more. "
Wagoner noted that
"In 1942, Campbell reported the induction of lung tumors in 20.3 percent of mice exposed
by inhaling dust from the Joachimsthal mines, whereas only 2.1 percent was found in the
unexposed controls. "
The most detailed and conclusive evidence showing the carcinogenic effect of radon
daughters has been done by Dr. Lafuma of the Radiation Protection Department of the Atomic
Energy Commission of France:
"Studies have been carried out by two teams from the Commission of Atomic Energy in
France. . . . Throughout the ten years of research, close to 10,000 rats were used of which
3,000 were used for radon studies. In these 3, 000 rats, more than 600 pulmonary cancers
were observed. "
Dr. Lafuma's research indicates a higher risk [per unit of exposure] at lower
cumulative working level months (WLM) .
It seems that the controversy over low level radiation which is now taking place is
following a similar pattern to that of the health hazards of cigarettes that began 30
years ago when epidemiological studies were met with flat denials that cigarettes could
possibly cause cancer of the lung.
One of the serious consequences of down-playing the effects of low-level radiation will be
to deny those who have developed various carcinomas adequate compensation which may be
their due. With the abundant information on the effects of low-level ionizing radiation,
the humane course of action would be to give the worker, or in most cases the deceased
worker's family, the benefit of the doubt as to whether his or her particular carcinoma
was a product of radiation, and compensate accordingly.
Society and industry must be willing to shoulder this burden if we wish to continue with
the production of nuclear power and nuclear weapons.
RADON RISK ESTIMATES: COMPARISON WITH A SAFE INDUSTRY
Mr. Bush, Manager of the Radiation Protection Division of the AECB, described mining as an
industry with high risk:
"one [accidental] death per year for every thousand workers"
According to Mr. Bush,
"Workers in the safest occupations -- manufacturing, for example -- are subject to an
annual risk of accidental death of about one in ten thousand. "
When asked whether the mining industry in Canada was an industry with a high standard of
safety, Mr. Bush replied: "No" . [In particular] he knew of no industry that exceeds
the combined risk of uranium mining.
According to the AECB,
"The risk of lung cancer associated with an exposure of 4 WLM per year over a normal
working life is considered to be acceptably small, compared to the risk of [accidental]
death associated with other ["safe"] industries. "
Mr. Bush re-iterated this in cross-examination:
6
"The risk of working with the present dose limits is no greater than the occupational risk
of the safer industries. "
Of course, what he clearly means is that the risk [from uranium mining] is no greater
than adding the occupational risk of a safer industry on top of the occupational risk of
an industry [mining] which does not have a high standard of safety.
[In any event] , the risk of accidental death in a "safe industry" can be approximated at
100 deaths per million workers per year. Several authors have produced estimates of lung
cancer cases per million people exposed to one working level month (WLM) . According to Mr.
Bush,
"Dr. Gordon Stuart, formerly of Chalk River, reviewed the American and Czechoslovakian
data and he concluded that . . . you get about 14 to 20 lung cancer cases per million people
exposed to one WLM.
"A year or two ago, the [European] Nuclear Energy Agency concluded that a reasonable
risk estimate, for purposes of radiation protection, would be about 100 cases of lung
cancer per million people per WLM. "
Sevc, in his calculations of the [Czechoslovakian] data in 1970, found
"0.23 ± 0.04 lung cancer cases per thousand workers per WLM [that is, 230 ± 40 lung
cancer cases per million workers per WLM] as an estimate of average radiation risk for
the total group. "
As can be seen, even using the Nuclear Energy Agency' s calculations, the [ cancer ]
risk to miners would be four times as great at present radiation standards [4 WLM per
year] than the accident risk in safe industries.
Using Sevc's calculations, [the cancer risk] would be 9.2 times as great --
approximately 10 times as great -- which would then be in a category of industries with a
high degree of risk [one accidental death per thousand workers per year] .
Moreover, there is a very important flaw in the AECB's comparison of accidental risks per
year with lung carcinomas, which makes direct comparison meaningless:
• Risk of accidental occupational death is a relatively instantaneous risk, which
exists (by definition) only during the period of employment and ends upon termination of
employment.
• Risk of lung cancer from radiation, although beginning after several years of
employment, continues many years past termination of employment; thus a gradually
flowering crop of cancers grows larger each year.
[Indeed] Archer & Linden in 1967 concluded that an exposure of 120 WLM
"appears to double the lung cancer incidence characteristic of the general [unexposed]
population. "
Summary of doubling dose estimates
for lung cancer in uranium miners:
Archer (1967) 120 WLM
Hewitt (1980) - Ontario 40-5O WLM
- Newfoundland 5O WLM
Sevc (1976) -50 WLM
7
US EPA (1980) -40 WLM
Ellett (1980) 40 WLM
BEIR-II (1972) 34 WLM
BCMA (1980) - NIOSH & Sevc 19-20 WLM
BEIR-III (198O) 12-17 WLM
Axelson (1980) 2 WLM
The lifetime incidence of lung cancer in males can be calculated to equal 52.5 per
thousand, equivalent to approximately a five percent lifetime risk for lung cancer
development in males. It would appear that the doubling dose from exposure to radon
daughters would be 40 WLM or less, in the exposure ranges experienced by today's miners.
Thus, at a lifetime dose of 40 WLM, a miner would have approximately a 10 percent rather
than a 5 percent risk of developing carcinoma of the lung; that is a risk of 1250 lung
cancer cases per million workers per WLM. The risk [per million workers] would be four
times as high at today's maximum permissible exposure of 4 WLM per year. Compare this
value with the risk of accidental death in safe industries of 100 accidental deaths per
million workers per year!
Because of the long latent period of lung cancer, and its variability with age and
smoking, Archer has calculated the attributable cancer for lifetime per million
[workers] per WLM, which is certainly the value most significant to the mining
population. Using the exposure rates present in today's mines and mills, the attributable
cancer per lifetime per WLM is approximately 1000 [per million workers] .
ATOMIC ENERGY CONTROL BOARD: UNFIT TO REGULATE
The AECB [Atomic Energy Control Board] policy regarding a lifetime exposure limit for
uranium miners [February 1978] is based on one study [published in 1969] , which is
not only 11 years out of date, but which has been revised several times by the authors.
The AECB notes in passing that in Ontario,
"only 20 of the 81 lung cancer victims who had worked in uranium mines had accumulated as
much as 120 WLM (the exposures of the other 61 victims being 0 to 99 WLM, or 35 WLM on
average)
Ignoring this and using the 1969 study (which seems to be the extent of their literature
review as no other references are cited) AECB states:
"If one had to choose a WLM value that had some special significance. 840 WLM would be a
more logical choice [than 120 WLM] because it marks the level above which lung cancer
incidence appears to increase with increasing exposure; (i.e. although an excess of lung
cancer is evident in each of the exposure categories, the excess appears to be independent
of exposure below 840 WLM. ) "
Such a policy statement, based on antiquated data and inadequate literature review, would
be irresponsible coming from the nuclear industry, let alone the regulatory agency of that
industry. However, as will become clear, it is difficult to ascertain where one ends and
the other begins.
The Manager of the Radiation Protection Division of the AECB is Mr. Bush, who has a degree
in Chemical Engineering (1955) . He worked for Atomic Energy of Canada Limited (AECL) in
Chalk River from 1957 to 1969, and subsequently with the AECB from 1969 to the present.
One notes that Mr. Bush is responsible for developing radiation protection guidelines and
regulations. Mr. Bush admitted,
8
"I'm not a medical doctor. I'm not an epidemiologist. "
(This is evident as well from the Board's paltry data analysis upon which their statements
of risk are made. ) The AECB
"is currently considering how the latest recommendations [on permissible radiation
exposures for workers and the public, put forward by the International Commission on
Radiological Protection - ICRP 1977] might be incorporated into AECB regulations. AECB
is being assisted in its review of the ICRP recommendations by its Advisory Committee on
Radiologic Protection [ACRP] , which it established early in 1979. The Advisory
Committee was set up to provide the Board with independent advice . . . no Board staff
member is [on it] . "
Mr. Bush pointed out the difficulty the U.S. Nuclear Regulatory Commission may have in
adopting these new ICRP higher dose limits:
"they would be difficult to implement under the climate of nuclear controversy currently
existing in the U.S.A. For example, the new ICRP system of dose limitation implies higher
dose limits for irradiation of some individual organs . . . "
The Chairman of the new Advisory Committee, Dr. G. C. Butler, listed members of this
Committee.
• It includes himself, who has been an employee of AECL at Chalk River from 1957
to 1965, a member of the ICRP Committee from 1963 to 1973 and again from 1973 to 1977, and
worked from 1945 to 1947 with the National Research Council (Ottawa) in the Atomic Energy
Project; he has been with the National Research Council since 1965.
• It also includes Dr. Marko of AECL [Director of Health Physics at Chalk River]
and Dr. Hollywood from Newfoundland, who wrote a section in the AECB Elliot Lake Uranium
Mine Inspector's Training Course Manual.
The [1979 Elliot Lake] manual contains the following:
o "The AECB has seen no convincing evidence for a limitation on cumulative lifetime
exposure, provided the average exposure received during a working life does not exceed 4
WLM per year. . . . "
o "Radiation damage is observed only at doses higher than about 100 rads; and although
effects have generally not been observed at lower doses, it is assumed for radiation
protection purposes that the effect is proportional to the dose right down to zero
exposure. "
Not only is the last sentence grossly in error, any trainee inspector who is using the
graph [showing "observed" cancers at low doses to be less than "expected" cancers
obtained by linear extrapolation] would be led to the incorrect conclusion that for all
radiation, the linear hypothesis will over-estimate the effects.
Other members [of ACRP] include Dr. Jan Muller from the Department of
Labour, Ontario, [who is of the opinion] that there is no serious risk at current
standards of 4 WLM per year of radon exposure, despite mounting evidence to the contrary.
No follow-up study on the Ontario uranium miners has been completed because the
information is still being processed by Dr. Muller. It is unfortunate, because of the
crucial nature of the Ontario studies, that there has been such a long delay since 1976.
It is hoped that this data will be available to the scientific community soon.
Dr. Butler also noted that his Committee did have Dr. Stuart from AECL, but that
he had now retired. [ACRP now includes both Dr. Myers and Dr. Newcombe, both of AECL. ]
Dr. Butler agreed that his Committee had not asked any independent bodies, such as the
Canadian Medical Association, the Royal College of Physicians and Surgeons, or the Royal
Society, to place a member of its own choice on the Committee.
The "independence" of this Committee must be seriously questioned. This lack of
"independence" is characteristic of the AECB.
9
As Dr. Bates [David Bates, M.D. , Chairman of the B.C. Royal Commission on Uranium
Mining] noted about the previous [AECB] Standing Committee on Safety,
"There appeared to be only one M.D. on it, and he had worked at Chalk River for all of his
life before that. "
RADON GAS IN HOMES: AN INDUSTRIALLY-INDUCED EPIDEMIC?
The Atomic Energy Control Board has announced adoption of radiation criteria for use in
the investigation and cleanup of communities contaminated by radiation.
The Government of British Columbia has adopted the AECB exposure limits [for public
exposure to radon daughters] .
"The WLM unit is not appropriate for exposures in the home or in other non-occupational
situations. In such situations the maximum permissible annual average concentration of
radon daughters (attributable to the operation of a nuclear facility) shall be 0.02 WL. "
[Outdoor] levels higher than 0.02 WL may be produced locally by uranium mines. Higher
outdoor concentrations would obviously produce higher indoor concentrations of radon.
[According to Dr. Wagoner:]
"On the basis of additional data, the EPA [U.S. Environmental Protection Agency] has
estimated that 110 to 230 extra lung cancer deaths would occur among 100,000 population
with a lifetime residency at ambient levels of radon daughter exposure (i.e. 0.004 WL) .
"In contrast, 2000 to 3000 extra lung cancer deaths per 100, 000 population were estimated
to occur over a lifetime indoor radon daughter exposure to 0.02 WL . "
In light of the present state of knowledge, one could well view the allowable exposure to
the public from nuclear facilities as tantamount to allowing an industrially-induced
epidemic of cancer.
Dr. Radford in his submission to the Commission stated that
"epidemiological and experimental evidence indicates that alpha radiation [from radon]
is more effective (per unit dose) in producing cancer when exposure is at low dose rates
over long periods of time, than when the equivalent dose is given at a high rate for short
periods of time. "
Dr. Archer observed that
"Alpha radiation [from radon] appears to be approximately eight times as efficient at
100 WLM as at 1000 WLM. This data makes it highly likely that radon daughter levels in
residences are responsible for some lung cancers. "
In 1971, the joint monograph by NIOSH [U.S. National Institute for Occupational Safety
and Health] and NIEHS [U.S. National Institute for Environmental Health Studies]
also noted:
"The risk of respiratory cancer per unit of exposure appeared to be greater in the lower
cumulative radiation groups than in the higher ones -- i.e. an assumption of linearity
appears not to be conservative [it may well under-estimate the actual risks] . "
Nevertheless, the AECB assumes that this [linear hypothesis]
"is a cautious assumption; i.e. the number of cancer cases will probably be
overestimated. "
AN OPEN LETTER FROM THE PRESIDENT OF THE
10
British Columbia Medical Association
13 January 1984
TO WHOM IT MAY CONCERN:
As there appears to be some confusion among representatives of industry and government
with respect to the British Columbia Medical Association's efforts as a major participant
in the British Columbia Royal Commission of Inquiry, Health and Environmental Protection
Uranium Mining, we wish to make the following comments:
1. Dr Eric R Young and Dr Robert F Woollard participated as interveners at the Inquiry
as representatives of this Association.
2 . Dr Young is presently the chairman of the environmental health committee of the
BCMA and Dr Woollard is past-chairman.
3 . During the Inquiry the BCMA was privileged to present statements of evidence of
internationally-recognized authorities on various aspects of this issue.
4 . The report entitled "The Health Dangers of Uranium Mining and Jurisdictional
Questions" authored by Drs Young and Woollard is the summary argument of the BCMA
presented in 1980 to the Royal Commission in response to its call for final arguments from
participants in the inquiry. As such it has been supported by the BCMA Executive and Board
of Directors.
5. This report has had significant peer review and there has been ample opportunity
for public comment.
6. The substance of the report is reflective of BCMA policies in the area of
environmental health as established over several years by consideration and debate at the
general assembly and Board of Directors and, as confirmation of this, the BCMA holds
copyright on both printings of this BCMA publication.
Extensive feedback has confirmed the report' s value as an aid in promoting public
participation in this important area of environmental health and has vindicated the
medical association's expressed interest to raise the level of debate on this issue.
Yours sincerely
G D McPherson, MD
BCMA President
This message, including any attachments, may contain information that is confidential and
proprietary information of Advanced Energy Industries, Inc. The dissemination,
distribution, use or copying of this message or any of its attachments is strictly
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11
BC Medical Association—Health Dangers of Uranium Mining Page 1 of 19
HEALTH DANGERS OF URANIUM MINING
AND JURISDICTIONAL QUESTIONS
The British Columbia
Medical Association
A SUMMARY OF MATERIAL
BEFORE THE
BRITISH COLUMBIA
ROYAL COMMISSION OF INQUIRY
HEALTH AND ENVIRONMENTAL PROTECTION
URANIUM MINING
PRESENTED: AUGUST 1980
BY
E.R. YOUNG, B.Sc., M.D.
R.F. WOOLLARD, M.D.
ON BEHALF OF
THE ENVIRONMENTAL HEALTH COMMITTEE OF
THE BRITISH COLUMBIA MEDICAL ASSOCIATION
ACADEMY OF MEDICINE BUILDING
1807 WEST 10TH AVENUE
VANCOUVER BC
Telephone (604) 736-5551
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Brief Summary of Major Points:
• Uranium Industry: Occupational Exposures
• Uranium Industry: Public Exposures
• Regulatory Framework: Setting Standards
Verbatim Excerpts from the 470 page report:
• LUNG CANCER AMONG UNDERGROUND MINERS
• MORE EVIDENCE ON LUNG CANCER AND RADON GAS
• RADON RISK ESTIMATES: Comparison with a Safe Industry
• ATOMIC ENERGY CONTROL BOARD: Unfit to Regulate
• RADON GAS IN HOMES: an Industrially-Induced Epidemic?
Clarification from the BCMA President
• AN OPEN LETTER:To Whom It May Concern
BCMA REPORT:
SUMMARY OF MAJOR POINTS
URANIUM INDUSTRY:
OCCUPATIONAL EXPOSURES
Delay of hazard recognition and consequent worker non-
protection is an unfortunate but recurring theme in the Canadian
regulatory and uranium industry history:
• Radon daughter radiation is a health hazard to workers in
advanced stages of exploration, such as in tunnels and shafts,
where very high levels of 1.6 working levels (WL) have been
recorded in low grade deposits (1600 times normal
background levels).
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• Average radon daughter levels in underground mines range
from 0.1 WL to about 1 WL (that is, 100 to 1000 times
normal background levels).
• In open-pit mines. the high density of radon (7.8 times
heavier than air) and atmospheric inversion conditions can
cause levels of from 2 to 10 WL in moderate to high grade
ore bodies.
• Workers in open pits with low to moderate grade ore receive
2 to 4 times the normal lifetime dose of radon daughter
radiation during their employment life, under conditions
where there are no inversions.
• In a uranium mill, with low to moderate grade ore, the
millers receive from 5 to 14 times the normal background
lifetime dose of radon daughter radiation during their 30-
year working lives.
• Uranium millers may receive doses of gamma radiation 1000
times background from high grade ores.
• Although the AECB assumes workers are receiving only a
small fraction of the annual limits, this is not borne out by
the facts.
• Despite AECB claims to the contrary, the risks from
radiation in uranium mining far exceed those of a "safe"
industry.
• The 4 WLM annual maximum permissible exposure to
radon and thoron daughters should be lowered to less than 1
WLM per year immediately, and serious consideration
should be given to lowering it to 0.4 WLM per year [ a
factor of 10 lower than present permissible levels J . This
would still exceed risks for a safe industry using AECB
criteria.
• The AECB is unfit to regulate uranium mining.
• Canada has lagged many years behind other countries in its
collection of cancer death statistics among uranium miners.
It is most unfortunate that there has been such a long delay
in publication of the follow-up study of the Elliot Lake
miners.
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• Nuclear industry proponents have tended to minimize risk
through lack of knowledge, generalizations, quoting outdated
studies, dilution of risk estimates, unsubstantiated
arguments, personal bias, basing conclusions on inadequate
studies, doublethink, and assuming workers cannot absorb
the full truth.
• The new ICRP weighting system [ based on the concept of
an "effective dose equivalent" I , if accepted, will permit
much larger doses of radiation at a time when reports
indicate that cancer risk is many times what it was
considered to be 22 years ago.
• AECB reliance on the ICRP as a basis for standards is
unwise. That body has become a political and social arbiter
rather than a scientific advisory group.
URANIUM INDUSTRY:
PUBLIC EXPOSURES
Uranium tailings will remain radioactive for hundreds of
thousands of years, and will require such expensive long-term
surveillance and maintenance by government and the local
citizenry as to make statements about uranium mining providing
revenue very misleading:
• Misuse of uranium tailings has led to internal lung doses
calculated to be 100 rems per year to the public.
• Conservative calculations show that the public near uranium
tailings will receive a 25 percent increase in lifetime radon
daughter radiation.
• Uranium tailings will have appreciable radioactivity for
more than 100,000 years.
• In Canada we now have approximately 100 million tons of
radioactive tailings; this will eventually increase to about one
billion tons by the year 2000.
• There have been many uranium tailings disasters in
Australia, Canada and the United States. even with the most
modern "state of the art" tailings dams.
• The present average allowable exposure to the public [ of
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0.02 WL of radon exposure ] could result in 200-300 extra
cases of lung cancer per 10,000 people per lifetime. In light of
current knowledge, this might be considered tantamount to
allowing an industrially induced and publicly sanctioned
epidemic of cancer.
• This present guideline of 0.02 WL must be immediately
withdrawn and replaced with "no exposure (above ambient
levels) of any carcinogen permitted to the local public".
• Radon contamination of ground water may be a health risk
in pincushion drilling typical of advanced exploration, yet
under present AECB regulations, a couple of hundred drill
holes can be made without obtaining a license. AECB
admitted to having no scientific data to show this is safe; the
regulation was based on an arbitrary administrative
decision.
• Radium-226 [ released from uranium tailings ] is a superb
producer of osteosarcoma [ bone cancer ] .
• In 1959 the ICRP recommended a maximum exposure of 3
picocuries per liter (pCi/1) of [ dissolved I radium-226 to the
public.
• In 1968 Canada allowed a maximum permissible
concentration of 100 picocuries per liter, with an objective of
10 picocuries per liter [ of dissolved radium-226 I .
• Ontario has retained a maximum permissible concentration
of 3 picocuries per liter I of dissolved radium-226 ] .
• New "recalculations" of the ICRP recommend relaxing the
radium-226 standard to 27 picocuries per liter (9 times the
Ontario limit of 3 picocuries per liter).
[ NOTE: Canada has since authorized this increase in
permissible radium levels in drinking water. ]
• Certain uranium mining companies in Ontario are
discharging radium-contaminated effluents which exceed the
standard of 3 picocuries per liter. With the relaxation of the
standard to 27 this will no longer be [ considered as ] a
technical or regulatory problem.
• American standards are as usual more stringent than
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Canada's; in the U.S.A., I dissolved I radium-226 plus
radium-228 cannot exceed 5 picocuries per liter.
• A U.S. Public Health Service study shows increased bone
cancer in communities with 4.2 picocuries per liter of
I dissolved ] radium-226 in drinking water, as compared
with communities having only 1 picocurie per liter.
• The concept that a radium-226 limit for the public can be set
ten times too high because the usual radium-226 levels will
only be one-tenth of that, is as inane as setting a speed limit
of 200 kilometers per hour in a school zone because most
caring people will only drive at 20 km/hr anyway.
• There are no standards for total radium-226 (dissolved and
particulate); one wonders if that is because total radium-226
effluents range as high as 168 picocuries per liter.
REGULATORY FRAMEWORK:
SETTING STANDARDS
The BCMA calls for an Emergency Task Force into tightening the
present radiation standards. Review by the AECB or by its
Committees is unacceptable; the Task Force should be under the
Advisory Council on Occupational Health and Safety or the
Science Council of Canada:
• Industry and regulatory officials are overly eager to select
conversion factors for dose calculations that are at the lower
end of the spectrum of values proposed. This consequently
leads to lower risk estimates of radiation effects. The fact
that the calculations are subject to "large unquantifiable
uncertainty" leaves one with little confidence in the
conclusions of health risks made by nuclear physicists and
former employees of Atomic Energy of Canada Limited, now
associated with the Atomic Energy Control Board.
• Canadian regulations lag far behind countries which are
more conscious and concerned about occupational and
public health and safety.
• Canadians cannot continue to allow vested interest
Ministries and regulatory bodies to promulgate maximum
permissible exposure levels ] of radiation ] .
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• The BCMA is on record as calling for a national enquiry into
nuclear energy in Canada, I including a total reassessment
of the structure and function of the AECB; this resolution
arose out of our investigations of nuclear waste management
and uranium mining.
• That the AECB consistently and seriously neglected its
statutory responsibility for the regulation of uranium mines
is obvious to the most casual observer.
• We believe that the continued use of the ALARA principle,
unenforced I guidelines, and the encouragement of
industrial self-regulation is a combination of objectives that
will [ continue to compromise the effectiveness of the
AECB as a regulator of uranium mining.
EXCERPTS FROM THE TEXT
OF THE BCMA REPORT
LUNG CANCER AMONG UNDERGROUND MINERS
Dr. Wagoner well described the discovery of the relationship between lung
cancer and radon daughters:
"The real nature of this pulmonary disorder among miners of the
Schneeberg (Germany) area was not identified until 1879 when Harting and
Hesse first diagnosed it.
"In 1913, Ainstein reported that of 665 Schneeberg miners dying during
1875-1912, 40 percent (or 276) died of lung cancer.
"Pircham and Sikl, in 1932, reported that of 17 deaths observed during
1929-1930 among miners of uranium-bearing ores in Joachimsthal
(Czechoslovakia), 53 percent (or 9) were due to cancer of the lung.
"These same investigators ... concluded that the most probable cause of
these tumors was radiation in the air of the mines. These investigators
also made note 'the miners themselves state that discovery of a rich uranium
vein is always followed some years later by a strongly increased mortality
among them'."
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Hollywood, in his article on "The Epidemiology of Lung Cancer Among
Workers Exposed to Radon and Radon Daughters" in May, 1979, noted:
"By 1940, then, excess deaths from lung cancer among two groups of
European miners had been associated with relatively high concentrations of
radon in the mine atmosphere. In that same year ... conclusions were drawn
that prolonged breathing of air containing a high concentration of
radon, may have caused what was estimated at that time to be a 30-fold
increase in the incidence of lung cancer.
"The percentage of miners developing carcinoma of the lungs in
Schneeberg was 63 percent, in Joachimsthal 42 percent, and in St.
Lawrence [Newfoundland[ 36 percent."
Studies in the U.S. were undertaken in the 1950's on uranium miners in the
Colorado Plateau area. These results began to appear in the early 60's, and they
showed an increase in lung cancer with an increase in exposure to radon
daughters. Dr. Wagoner noted that these studies had to be extended and refined to
rule out any possible other agent:
"First there was a basic denial that there was such a problem. Then
there was a position that it had to be due to smoking. Then it was on the
basis -- well, it had to be due to hard rock mining. There were sequential
analyses undertaken to address all of these, what in statistical terms I would
call confounding factors, but in public health terms I would call delaying
[factors] .
"In 1967, Lunden demonstrated that during the period 1950 through June
1965, white underground uranium miners experienced 37 deaths due to
lung cancer whereas only 7.3 would have been expected [and] through
September 1967, 62 deaths due to lung cancer as contrasted to only 10.02
expected."
[As noted by Dr. Wagoner, referring to the Colorado data] , observed versus
expected carcinoma of the lung cases in 1978 was 205 versus 40, with an
attributable risk of 164 men
"who have died due to lung cancer over and above what I would expect in
that population if they had not been subjected to those exposures. I would
consider that as epidemic."
With the long latent period of carcinoma induction by low level radiation, these
numbers will increase further over the next 20 years.
The submission of Dr. Wigle relating to the St. Lawrence (Newfoundland)
fluorspar miners who were exposed to elevated levels of radon daughters
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demonstrated an observed incidence of lung cancer of 65 versus an expected
6.41, with an average ratio of observed to expected of 10.1 . Dr. Radford noted
that the ongoing studies, such as the one of the Newfoundland fluorspar miners,
"clearly indicate the seriousness of this problem, still with us fifty years
after the risk was originally identified in the Bohemian miners of central
Europe."
The collection of the Canadian [uranium mining[ data began in 1974. The
Royal Commission on Health and Safety in Mines in Ontario [the Ham
Commission] commissioned an epidemiological study of the uranium miners in
the Elliot Lake area; this was conducted from 1975 to 1976. Dr. Muller noted that
"The Ontario uranium mining population is characterized by relatively
low exposures and relatively short periods of exposure. There is,
therefore, less extrapolation involved from high to low doses and dose
rates, ... relatively short periods of exposure in most men, ... and nearly 20
years of observation time."
The Ham Commission analyzed the data [81 observed lung cancer deaths
versus 45.08 expected] in order to determine whether radon daughters were the
agent:
"The lung cancer cases tended to accumulate more in the higher exposure
groups, which indicates that lung cancer risk was greater in the higher
exposure groups than in the lower ones."
In his analysis of the Ontario data, Ellett stated:
"From the occupational health point of view, it is certain that exposure to
radon daughters leads to an increased risk of lung cancer for the
working force as a whole, and that this risk extends to levels of
exposure that are below current occupational guidelines."
According to the United Steelworkers of America, the number of lung cancer
cases should now read well in excess of 100 at Elliot Lake and are "climbing
steadily".
MORE EVIDENCE ON LUNG CANCER AND RADON GAS
Dr. Axelson, in his submission on Swedish Miner Lung Carcinoma, stated:
"Several studies have shown an increased lung cancer mortality among
Swedish metal [zinc-lead-iron] miners as probably caused by the
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exposure to radon and radon daughters in the mine atmosphere. In a
nation-wide survey, as yet unpublished, the average lung cancer mortality
among Swedish miners was found to be about fivefold the normal.
"These Swedish studies deal with a life-time follow-up of miners, whereas
most other mining populations have been studied by means of cohorts with
a follow-up time of not less than about 2S-30 years or more."
Wagoner noted that
"In 1942, Campbell reported the induction of lung tumors in 20.3 percent of
mice exposed by inhaling dust from the Joachimsthal mines, whereas only
2.1 percent was found in the unexposed controls."
The most detailed and conclusive evidence showing the carcinogenic effect of
radon daughters has been done by Dr. Lafuma of the Radiation Protection
Department of the Atomic Energy Commission of France:
"Studies have been carried out by two teams from the Commission of
Atomic Energy in France.... Throughout the ten years of research, close to
10,000 rats were used of which 3,000 were used for radon studies. In
these 3,000 rats, more than 600 pulmonary cancers were observed."
Dr. Lafuma's research indicates a higher risk [per unit of exposure] at lower
cumulative working level months (WLM).
It seems that the controversy over low level radiation which is now taking
place is following a similar pattern to that of the health hazards of cigarettes
that began 30 years ago when epidemiological studies were met with flat
denials that cigarettes could possibly cause cancer of the lung.
One of the serious consequences of down-playing the effects of low-level
radiation will be to deny those who have developed various carcinomas
adequate compensation which may be their due. With the abundant
information on the effects of low-level ionizing radiation, the humane course
of action would be to give the worker, or in most cases the deceased worker's
family, the benefit of the doubt as to whether his or her particular
carcinoma was a product of radiation, and compensate accordingly.
Society and industry must be willing to shoulder this burden if we wish to
continue with the production of nuclear power and nuclear weapons.
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RADON RISK ESTIMATES: COMPARISON WITH A SAFE INDUSTRY
Mr. Bush, Manager of the Radiation Protection Division of the AECB, described
mining as an industry with high risk:
"one [accidental] death per year for every thousand workers"
According to Mr. Bush,
"Workers in the safest occupations -- manufacturing, for example -- are
subject to an annual risk of accidental death of about one in ten
thousand."
When asked whether the mining industry in Canada was an industry with a high
standard of safety, Mr. Bush replied: "No". [In particular] he knew of no
industry that exceeds the combined risk of uranium mining.
According to the AECB,
"The risk of lung cancer associated with an exposure of 4 WLM per year
over a normal working life is considered to be acceptably small, compared
to the risk of [accidental] death associated with other ["safe"]
industries."
Mr. Bush re-iterated this in cross-examination:
"The risk of working with the present dose limits is no greater than the
occupational risk of the safer industries."
Of course, what he clearly means is that the risk [from uranium mining] is no
greater than adding the occupational risk of a safer industry on top of the
occupational risk of an industry [mining] which does not have a high standard
of safety.
[In any event] , the risk of accidental death in a "safe industry" can be
approximated at 100 deaths per million workers per year. Several authors have
produced estimates of lung cancer cases per million people exposed to one
working level month (WLM). According to Mr. Bush,
"Dr. Gordon Stuart, formerly of Chalk River, reviewed the American and
Czechoslovakian data and he concluded that ... you get about 14 to 20 lung
cancer cases per million people exposed to one WLM.
"A year or two ago, the [European] Nuclear Energy Agency concluded
that a reasonable risk estimate, for purposes of radiation protection, would
be about 100 cases of lung cancer per million people per WLM."
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Sevc, in his calculations of the [Czechoslovakian] data in 1970, found
"0.23 ± 0.04 lung cancer cases per thousand workers per WLM [that is,
230 ± 40 lung cancer cases per million workers per WLM] as an estimate
of average radiation risk for the total group."
As can be seen, even using the Nuclear Energy Agency's calculations, the
[ cancer ] risk to miners would be four times as great at present radiation
standards [4 WLM per year] than the accident risk in safe industries.
Using Sevc's calculations, [the cancer risk] would be 9.2 times as great --
approximately 10 times as great -- which would then be in a category of
industries with a high degree of risk [one accidental death per thousand workers
per year] .
Moreover, there is a very important flaw in the AECB's comparison of accidental
risks per year with lung carcinomas, which makes direct comparison
meaningless:
• Risk of accidental occupational death is a relatively instantaneous risk,
which exists (by definition) only during the period of employment and ends
upon termination of employment.
• Risk of lung cancer from radiation, although beginning after several years
of employment, continues many years past termination of employment;
thus a gradually flowering crop of cancers grows larger each year.
[Indeed] Archer & Linden in 1967 concluded that an exposure of 120 WLM
"appears to double the lung cancer incidence characteristic of the general
[unexposed] population."
Summary of doubling dose estimates
for lung cancer in uranium miners:
Archer (1967) 120 WLM
Hewitt (1980) - Ontario 40-5O WLM
- Newfoundland 5O WLM
Sevc (1976) -50 WLM
US EPA (1980) -40 WLM
Ellett (1980) 40 WLM
BEIR-II (1972) 34 WLM
BCMA (1980) - NIOSH & Sevc 19-20 WLM
BEIR-III (198O) 12-17 WLM
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Axelson (1980) 2 WLM
The lifetime incidence of lung cancer in males can be calculated to equal 52.5 per
thousand, equivalent to approximately a five percent lifetime risk for lung cancer
development in males. It would appear that the doubling dose from exposure to
radon daughters would be 40 WLM or less, in the exposure ranges experienced
by today's miners.
Thus, at a lifetime dose of 40 WLM, a miner would have approximately a 10
percent rather than a 5 percent risk of developing carcinoma of the lung;
that is a risk of 1250 lung cancer cases per million workers per WLM. The
risk [per million workers' would be four times as high at today's
maximum permissible exposure of 4 WLM per year. Compare this value
with the risk of accidental death in safe industries of 100 accidental deaths
per million workers per year!
Because of the long latent period of lung cancer, and its variability with age and
smoking, Archer has calculated the attributable cancer for lifetime per million
[workers] per WLM, which is certainly the value most significant to the mining
population. Using the exposure rates present in today's mines and mills, the
attributable cancer per lifetime per WLM is approximately 1000 [per million
workers] .
ATOMIC ENERGY CONTROL BOARD: UNFIT TO REGULATE
The AECB [Atomic Energy Control Board] policy regarding a lifetime
exposure limit for uranium miners [February 1978] is based on one study
[published in 1969] , which is not only 11 years out of date, but which has been
revised several times by the authors. The AECB notes in passing that in Ontario,
"only 20 of the 81 lung cancer victims who had worked in uranium mines
had accumulated as much as 120 WLM (the exposures of the other 61
victims being 0 to 99 WLM, or 35 WLM on average)."
Ignoring this and using the 1969 study (which seems to be the extent of their
literature review as no other references are cited) AECB states:
"If one had to choose a WLM value that had some special significance 840
WLM would be a more logical choice [than 120 WLM] because it marks
the level above which lung cancer incidence appears to increase with
increasing exposure; (i.e. although an excess of lung cancer is evident in
each of the exposure categories, the excess appears to be independent of
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exposure below 840 WLM.)"
Such a policy statement, based on antiquated data and inadequate literature
review, would be irresponsible coming from the nuclear industry, let alone
the regulatory agency of that industry. However, as will become clear, it is
difficult to ascertain where one ends and the other begins.
The Manager of the Radiation Protection Division of the AECB is Mr. Bush, who
has a degree in Chemical Engineering (1955). He worked for Atomic Energy of
Canada Limited (AECL) in Chalk River from 1957 to 1969, and subsequently
with the AECB from 1969 to the present. One notes that Mr. Bush is responsible
for developing radiation protection guidelines and regulations. Mr. Bush
admitted,
"I'm not a medical doctor. I'm not an epidemiologist."
(This is evident as well from the Board's paltry data analysis upon which their
statements of risk are made.) The AECB
"is currently considering how the latest recommendations [on permissible
radiation exposures for workers and the public, put forward by the
International Commission on Radiological Protection — ICRP 1977]
might be incorporated into AECB regulations. AECB is being assisted in its
review of the ICRP recommendations by its Advisory Committee on
Radiologic Protection [ACRP] , which it established early in 1979. The
Advisory Committee was set up to provide the Board with independent
advice ... no Board staff member is [on it] ."
Mr. Bush pointed out the difficulty the U.S. Nuclear Regulatory Commission
may have in adopting these new ICRP higher dose limits:
"they would be difficult to implement under the climate of nuclear
controversy currently existing in the U.S.A. For example, the new ICRP
system of dose limitation implies higher dose limits for irradiation of some
individual organs ..."
The Chairman of the new Advisory Committee, Dr. G. C. Butler, listed
members of this Committee.
• It includes himself, who has been an employee of AECL at Chalk River
from 1957 to 1965, a member of the ICRP Committee from 1963 to 1973
and again from 1973 to 1977, and worked from 1945 to 1947 with the
National Research Council (Ottawa) in the Atomic Energy Project; he has
been with the National Research Council since 1965.
• It also includes Dr. Marko of AECL [Director of Health Physics at
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Chalk River] and Dr. Hollywood from Newfoundland, who wrote a
section in the AECB Elliot Lake Uranium Mine Inspector's Training
Course Manual.
The [1979 Elliot Lake] manual contains the following:
o "The AECB has seen no convincing evidence for a limitation on
cumulative lifetime exposure, provided the average exposure received
during a working life does not exceed 4 WLM per year...."
o "Radiation damage is observed only at doses higher than about 100
rads; and although effects have generally not been observed at lower
doses, it is assumed for radiation protection purposes that the effect is
proportional to the dose right down to zero exposure."
Not only is the last sentence grossly in error, any trainee inspector who is
using the graph [showing "observed" cancers at low doses to be less than
"expected" cancers obtained by linear extrapolation] would be led to the
incorrect conclusion that for all radiation, the linear hypothesis will over-
estimate the effects.
. Other members [of ACRP] include Dr. Jan Muller from the Department
of Labour, Ontario, [who is of the opinion] that there is no serious risk at
current standards of 4 WLM per year of radon exposure, despite mounting
evidence to the contrary. No follow-up study on the Ontario uranium miners
has been completed because the information is still being processed by Dr.
Muller. It is unfortunate, because of the crucial nature of the Ontario
studies, that there has been such a long delay since 1976. It is hoped that
this data will be available to the scientific community soon.
• Dr. Butler also noted that his Committee did have Dr. Stuart from AECL,
but that he had now retired. [ACRP now includes both Dr. Myers and Dr.
Newcombe, both of AECL.]
Dr. Butler agreed that his Committee had not asked any independent bodies, such
as the Canadian Medical Association, the Royal College of Physicians and
Surgeons, or the Royal Society, to place a member of its own choice on the
Committee.
The "independence" of this Committee must be seriously questioned. This
lack of"independence" is characteristic of the AECB.
As Dr. Bates [David Bates, M.D., Chairman of the B.C. Royal Commission on
Uranium Mining] noted about the previous [AECB] Standing Committee on
Safety,
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"There appeared to be only one M.D. on it, and he had worked at Chalk
River for all of his life before that."
RADON GAS IN HOMES: AN INDUSTRIALLY-INDUCED EPIDEMIC?
The Atomic Energy Control Board has announced adoption of radiation criteria
for use in the investigation and cleanup of communities contaminated by
radiation.
The Government of British Columbia has adopted the AECB exposure
limits [for public exposure to radon daughters] :
"The WLM unit is not appropriate for exposures in the home or in
other non-occupational situations. In such situations the maximum
permissible annual average concentration of radon daughters
(attributable to the operation of a nuclear facility) shall be 0.02 WL."
[Outdoor] levels higher than 0.02 WL may be produced locally by uranium
mines. Higher outdoor concentrations would obviously produce higher indoor
concentrations of radon. [According to Dr. Wagoner:]
"On the basis of additional data, the EPA [U.S. Environmental Protection
Agency] has estimated that 110 to 230 extra lung cancer deaths would
occur among 100,000 population with a lifetime residency at ambient levels
of radon daughter exposure (i.e. 0.004 WL).
"In contrast, 2000 to 3000 extra lung cancer deaths per 100,000
population were estimated to occur over a lifetime indoor radon
daughter exposure to 0.02 WL ."
In light of the present state of knowledge, one could well view the allowable
exposure to the public from nuclear facilities as tantamount to allowing an
industrially-induced epidemic of cancer.
Dr. Radford in his submission to the Commission stated that
"epidemiological and experimental evidence indicates that alpha radiation
[from radon] is more effective (per unit dose) in producing cancer when
exposure is at low dose rates over long periods of time, than when the
equivalent dose is given at a high rate for short periods of time."
Dr. Archer observed that
"Alpha radiation [from radon] appears to be approximately eight times as
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efficient at 100 WLM as at 1000 WLM. This data makes it highly likely
that radon daughter levels in residences are responsible for some lung
cancers."
In 1971, the joint monograph by NIOSH [U.S. National Institute for
Occupational Safety and Health] and NIEHS [U.S. National Institute for
Environmental Health Studies] also noted:
"The risk of respiratory cancer per unit of exposure appeared to be greater
in the lower cumulative radiation groups than in the higher ones -- i.e. an
assumption of linearity appears not to be conservative [it may well under-
estimate the actual risks] ."
Nevertheless, the AECB assumes that this [linear hypothesis]
"is a cautious assumption; i.e. the number of cancer cases will probably be
overestimated."
AN OPEN LETTER FROM THE PRESIDENT OF THE
British Columbia Medical Association
13 January 1984
TO WHOM IT MAY CONCERN:
As there appears to be some confusion among representatives of industry and
government with respect to the British Columbia Medical Association's efforts as
a major participant in the British Columbia Royal Commission of Inquiry, Health
and Environmental Protection Uranium Mining, we wish to make the following
comments:
1. Dr Eric R Young and Dr Robert F Woollard participated as interveners at
the Inquiry as representatives of this Association.
2. Dr Young is presently the chairman of the environmental health committee
of the BCMA and Dr Woollard is past-chairman.
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BC Medical Association—Health Dangers of Uranium Mining Page 18 of 19
3. During the Inquiry the BCMA was privileged to present statements of
evidence of internationally-recognized authorities on various aspects of this
issue.
4. The report entitled "The Health Dangers of Uranium Mining and
Jurisdictional Questions" authored by Drs Young and Woollard is the
summary argument of the BCMA presented in 1980 to the Royal
Commission in response to its call for final arguments from participants in
the inquiry. As such it has been supported by the BCMA Executive and
Board of Directors.
5. This report has had significant peer review and there has been ample
opportunity for public comment.
6. The substance of the report is reflective of BCMA policies in the area of
environmental health as established over several years by consideration and
debate at the general assembly and Board of Directors and, as confirmation
of this, the BCMA holds copyright on both printings of this BCMA
publication.
Extensive feedback has confirmed the report's value as an aid in promoting
public participation in this important area of environmental health and has
vindicated the medical association's expressed interest to raise the level of debate
on this issue.
Yours sincerely
G D McPherson, MD
BCMA President
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BC Medical Association—Health Dangers of Uranium Mining Page 19 of 19
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