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Brennain Lloyd, Northwatch's picture
Mar 4, 2021 - 09:16

While we appreciate that the intent of the discussion papers was to provide a brief overview, but the paper on waste "minimization" used a lot of its page space to describe current practices (strategies vs policy) but was selective in how it presented current practices.
In the context of a paper that described current practices, the NRCan Discussion Paper on Waste Minimization was selective in how it presented current practices, or even the range of current practices. It also excluded any analysis of the health, social or environmental consequences of these practices. For example, the following areas are directly relevant, but where either missing or inadequate in their presentation:
- Descriptions of current practices and operations in Canada that are only very generally referred to in the description of strategies but are not even explicitly identified, including incineration of low level radioactive waste, compaction, and export of radioactive wastes internationally for “processing” and the required repatriation of concentrations of those radioactive wastes
- Discussion of environmental and health effects and risks related to minimization practices, such as incineration
- Discussion of “Clearance” levels for radioactive wastes, and the relationship between clearance levels and the free release of radioactively contaminated materials into landfills and municipal water systems, including the policies and principles that seemingly allow these practices in Canada
- Policy implications of “recycling” or reprocessing of radioactive wastes, including as it relates to the potential contamination of metal streams, such as steel, and related concerns around security and proliferation in the case of recycling or reprocessing high level nuclear fuel waste
- Principles of protection of human health and the environment in relationship to preventing or mitigating the known or potential health and environmental impacts of radioactive waste reprocessing / recycling
- Linkages between this discussion paper and the decommissioning discussion paper, particularly related to clearance levels for the decommissioning of radioactive sites or clean up projects such as at Port Hope

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