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Nuclear regulatory agencies recommend against including radionuclides as potential CMC

In 2014, Environment and Climate Change Canada (ECCC) and the U.S. Environmental Protection Agency (USEPA) invited stakeholders to nominate substances for potential listing as chemicals of mutual concern (CMC) under Annex 3 of the Great Lakes Water Quality Agreement.  Environmental NGOs and other stakeholder groups responded to this invitation by nominating radionuclides (among other substances) for evaluation during the second round of CMC listing activities.

As part of their deliberations regarding whether radionuclides should be evaluated as a potential CMC, ECCC and EPA sought input from the federal agencies responsible for regulation of nuclear materials in their respective countries. ECCC and EPA released the agencies’ response at the Great Lakes Executive Committee meeting in Toronto on December 5-6, 2017. Both agencies have concluded that radionuclides should not be designated as chemicals of mutual concern.

The Canadian Nuclear Safety Commission (CNSC) found “no evidence to indicate that radionuclides currently within the Great Lakes are posing an unreasonable risk to the environment, or human health and safety.” Noting that radionuclides are currently among the most heavily regulated substances in the world, the CNSC stated that its job is to “ensure Canada’s nuclear industry is protective of the environment and the health and safety of persons.” The CNSC concluded that “strong intergovernmental relationships have been established both federally and provincially to ensure radionuclides and radiation are safely managed.”

The NRC noted that it has “a robust regulatory regime that protects public health and the environment, and that provides for substantive transparency and public involvement.” According to the NRC, its regulatory program has been successful in ensuring that any radionuclide releases from NRC-licensed facilities into the environment have had a negligible impact on the water quality of the Great Lakes. NRC further concluded that “[b]ecause the existing regulatory framework ensures a very low risk from radiation exposure, the NRC believes there is no safety benefit for additional regulation of radionuclides as chemicals of mutual concern.”

Both the CNSC and RNC responses refute the NGO petitioners’ conclusion that “… there is no level of radionuclides below which exposure can be defined as ‘safe;’ therefore, very low levels of exposure can be significant.” Both agencies state that this claim is incorrect, and that it is very difficult to establish the risk of low doses over a lifetime because the risk “is not known with certainty and could be zero.”

ECCC and U.S. EPA are considering these recommendations as they prepare to move forward to review a new set of substances for potential CMC listing later this year. The documents produced by the two nuclear regulatory agencies are available to members here.