To Whom It May Concern,…

   To Whom It May Concern,

 EBR Registry Number: 013-0560

  This submission is being sent on behalf of the Bruce Peninsula Environment Group (BPEG). BPEG was founded in 1989 and was incorporated several years later. The Board of Directors and the members of BPEG are holding monthly meetings in Lion's Head, Bruce County.

  We are focusing in this submission on the recommendations in the List of Proposed Changes to the Provincial Nuclear Emergency Response Plan 2009 (http://www.energy.gov.on.ca/en/files/2017/05/PNERP_Changes.pdf), specifically Section 2.6- Population Groups.

  Sec 2.6 - Population Groups

 Current- The need for a protective measure to take into account the projected dose to the most exposed individual in the Critical, Vulnerable and Special Groups.

  Proposed Changes-The revised PNERP to be aligned with revised Health Canada Guidance on population groups.

  We have particular problems with the references to the radiation exposure limits for vulnerable groups of the population.  Health Canada Guidance for 'Intervention During a Nuclear Emergency' are very controversial. They are in one part, focusing on children and then when it comes to the crunch, they seem to promote using the exposure limits for all of the general public. That Health Canada Guidance then also refer to the provincial health agency guidelines. They state that in most cases, provincial guidelines supersede the federal ones.

  Of course, with the choice of the exposure limits, Ontario's provincial health agency always uses the Canadian Nuclear Safety Commission (CNSC) as a reference agency. As we have dealt with the CNSC in many of their nuclear reactor operating license hearings, we have not found any updating of their public exposure limits from their decade long derived exposure limit of 1 mSv per year for the general public. They don't make any differentiation to protect vulnerable population groups.

 It would be a grave mistake to adopt CNSCs regulated limits as it does not take into account the extreme health effects of exposure on the female gender. Science for the Vulnerable: Setting Radiation and Multiple Exposure Standards (https://ieer.org/resource/depleted-uranium/science-vulnerable-setting-radiation/) and also the findings of the widely known and well-regarded U.S. organization Physicians for Social Responsibility (PSR) in their document RADIATION AND PUBLIC HEALTH (www.psr.org/resources/radiation-and-public-health.pdf) both illustrate the need for different regulated exposure limits.  The 2016 census shows that are more than half a million more people of female gender in Canada's population than of the male gender and more specifically, Ontario's female population is several ten thousands higher than the male. In other words, if the recommended change is adopted, more than half of our population would not be protected from the health effects of nuclear accidents using CNSCs public exposure limits.

  We urgently recommend that the revised PNERP shows the need for special treatment for the female population, as far as sheltering and evacuation procedures are concerned. Of course, children and pregnant mothers especially need to be accounted for.  There needs to be annually updated statistics to record the numbers.

  We urgently recommend that our concerns are properly recognized and that action is taken to update the Provincial Nuclear Emergency Response Plan to protect the female population.

[Original Comment ID: 210119]