I largely agree with the policy as written - I believe it makes sense to keep the spent fuel (HLW) at the generation sites since these sites already have a security presence onsite and the building footprint for HLW is a small portion of the overall site. Furthermore, it makes sense to keep the HLW onsite rather than spending the resources to transport to a different interim storage facility - keeping it close to the site of production also makes transportation easier, more cost effective, and safer. My only question is in regards to SMRs/MMRs - in this case should there be a provision added in the policy in which these would be stored in a centralized location? For these reactor designs since they are smaller in size the supporting infrastructure and personnel are much smaller so it may make sense to store the "spent fuel" in a centralized location.
I'd encourage those not familiar with spent nuclear fuel to do some research and you would be amazed to learn that spent nuclear fuel is composed of solid ceramic (UO2) fuel pellets which look almost identical to the fresh UO2 fuel and workers standing next to the concrete/MACSTOR/dry storage contains receive dose rates well below regulatory limits.
I'd recommend that NRCan to continue with the Adaptive Phase management which utilizes storage rather than direct disposal as the Gen 4/breeder reactors and future designs will be able to utilize the "spent fuel" as feedstock and directly burying "spent fuel" (which still contains a large amount of usable energy) would just lead to extra resourced needed in the future to retrieve the direct disposal fuel.