Requirements for “waste characterization,” a key step in ensuring safety, are essentially non-existent in the proposed license.
At three places the EA report says “Under CNSC licence, CNL would also have to comply with the CNSC waste characterization requirements as outlined in CNSC Regulatory Document, REGDOC-18.104.22.168, volume 1.”
Three problems with that statement:
1) There is no such REGDOC, although there IS a REGDOC-2.11.1, Volume I
2) However, REGDOC-2.11.1, Volume I is NOT included in the CNSC licence, so CNL would not have to comply with it.
3) And even if REGDOC-2.11.1, Volume I WERE included in the CNSC licence, it contains no substantial requirements for waste characterization:
7.2 Waste characterization The licensee shall perform waste characterization at appropriate steps in the management of radioactive waste. The characterization of radioactive waste shall include the principal radionuclides relevant to safety and assurance that the waste or waste package will meet the acceptance criteria for the appropriate steps in the management of radioactive waste. Waste characterization shall include assessing the physical, mechanical, chemical, biological, thermal and/or radiological properties of the waste, including dominant radionuclide content, as applicable. The licensee shall maintain records of the relevant characteristics of the waste based on the characterization performed.
Assessing only “principal” or “dominant” radionuclides is subjective. This means that the licensee can choose to ignore most of the radionuclides in the waste, making it impossible to track them and adhere to limits in the Waste Acceptance Criteria. The phrase “as applicable” means that even tracking “dominant” radionuclides is optional.