1. THAT for ten years I have been a member of the Canadian Physicians for the Prevention of Nuclear War (CPPNW) and for ten years have served on the Provincial Executive of that organization, which is an affiliate of the International Physicians for the Prevention of Nuclear War. In 1985, the International Physicians for the Prevention of Nuclear War was awarded the Nobel Peace Prize for its ongoing work in lessening the likelihood of nuclear war. In this capacity I have studied port visits in terms of their potential medical consequences. I co-authored, with Professor Michael D. Wallace, the paper "Military Related Threats To The B.C. Environment", now attached as Exhibit "A" to this my affidavit. We submitted this paper to the British Columbia Ministry of the Environment. I have some expertise concerning the port visits of such ships in British Columbia.
2. THAT I have developed a special interest in the radiation field because of my work with CPPNW. I have studied the effects of such disasters as Chernobyl. I have familiarized myself, for instance, with the Jackson Davis report, Nuclear Accidents on Military Vessels in Canadian Ports cited in my accompanying paper, "Military Related Environmental Hazards Affecting British Columbia".
3. THAT it is my considered opinion, as argued in the aforementioned paper, now attached as Exhibit "B", that a major accident involving a ship's nuclear reactor could have catastrophic effects on the health of British Columbians, both immediately and in the long term. In the case of any explosion or reactor accident, there are both the acute traumatic injuries directly attributable to the event, and the immediate effects of radiation poisoning. The acute phase can last many weeks, as we saw at Chernobyl, but the long term effects are even more insidious. They include carcinogenesis (the change from normal cells to cancer cells), genetic damage (infertility, chromosomal damage), changes to the immune system, and long term effects of radiation damage (fibrosis of the lungs, damage to the gastrointestinal tract, etc.).
4. THAT any of the above scenarios could result in a significant number of casualties. Given our lack of preparedness, and the relatively small number of people trained to deal with such problems, the medical system would soon be overwhelmed. In the case of an explosion or shipboard fire in a nuclear-powered ship in Esquimalt harbour, the two major hospitals in the area (Royal Jubilee and Victoria General) would be within a 5 kilometre evacuation zone, which would close all designated burn beds in the Greater Victoria area.
5. THAT the exact number and nature of the injuries would, be course, vary with the scenario. As an illustration, consider the case of a nuclear reactor accident in a major port. The people in the immediate area, if they have survived, could be assumed to suffer a variety of traumatic injuries, such as burns, lacerations, fractures, and crush injuries. Immediately following the accident, fission products, comprising a wide variety of radionuclides and transuranics, would be released. Anyone exposed to 100 rads or more will develop acute radiation sickness, whose dominant features include nausea, vomiting, prostration, and confusion. Changes in the bone marrow occur a little later, resulting in immunosuppression and anemia. Death is a certainty at around 700 rads total body dose, although patients sometimes survive for some weeks.
6. THAT even some distance from the radiation source, contamination occurs by cloudshine, ground deposition, and inhalation exposure. Levels will vary with climatic condition and prevailing winds, but could easily exceed 1,000,000 times normal background radiation levels. Assuming an accident involving a 10 megawatt naval propulsion reactor, computer models would suggest 400 to 4,000 additional cancer deaths. If the area was not immediately evacuated, the total would be much higher. Several aspects of the physical geography of the Victoria area would complicate and show evacuation, thus worsening the situation.
7. THAT as a medical practitioner, I believe that the only reasonable way of dealing with radiation accidents is to prevent the, as medical response cannot possibly be adequate. I firmly believe that, although the probability of an accident on a nuclear ship may be small, that the possible consequences are so devastating that the resultant risk is unacceptable.

SWORN in the City of White Rock, Province of British Columbia, February, 1992

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