Thank you for this opportunity to provide comments.

Full disclosure: As a former Director of the  UMMD (retired 2012) and an Expert Consultant with the IAEA (2012-2024), I trust my feedback carries some value.

First off, I was a little surprised with the quality of the document posted for public review. There are a number of simple typo errors and simple editing that could have improved the quality of document. That is a simple fix and presume next round will correct that.

In one of my latest contributions to an IAEA document about Milestones in the Uranium Production Cycle, we corrected an important misnomer about the term “waste rock”. And I see that struggle continues in the draft REGDOC. A better term is to call it ‘mine rock’, and then clarify its quality after. As not all mine rock needs to be treated as a “waste”. That is an old holdover term when mine production defined waste as anything that is not ore.

Taking just one example excerpt early in the IAEA document, we  talk about identifying mine rock even in the exploration drill program:

"Finally, it provides information on the amount of mine rock that will be generated during the development and mining phases. Adequate segregation and management, including storage and treatment where appropriate, of mine rock material (including radiologically free clean rock and mineralized radioactive

(contaminated) waste rock) from a safety and environmental perspective also need to be considered. Clean mine rock is a valuable construction material, and this asset needs to be identified early in the process."

This is an opportunity the CNSC can improve this description too and move the document forward into a more understandable format for all interested parties to understand.

There is also a harmonized regulatory role that is unique to uranium mines and mills, where the province or territory also has jurisdiction that can line up with the CNSC.  This has been a very formal agreement that has been in place for four decades or more with Sask., in one form or another.  Recognizing and empowering a harmonized and cooperative regulatory process has been promoted at the IAEA for at least of couple of decades too.  How this can improve the efficiencies of regulatory oversight for uranium mining and milling should be explained.

There are a couple of terms that need to be better controlled or explained: "sufficient" or "adequate".   As a guide to submitting a licence application, these types of words must be used in a clear manner.

Another big legal question:  If this is a a “guide”, must it be followed as such, or will it be imposed as a “requirement “ of information on submission?  Is Guide the correct term?

In the discussion on each SCA, please identify where and how these apply to each stage of the life-cycle of the facility.

Thank you, and I look forward to the inputs of others, and the subsequent revisions.

Cheers! 

Prior to retiring from the CNSC in early 2012, another colleague and I worked on proposed revisions to the U Mines and Mills Regulations.
Fred Ashley, myself and a working group in Ottawa, including staff from Legal Services, had initiated improvements and clarification to those Regs.
That included:
-Inclusion of in situ solution  recovery of the ore ( as Denison is now proposing in NE Sask)
- expanding the definition of exploration, to better define “intensive exploration”. An area still under control of the province or territories, as long as the exploration (including a test mine) did NOT include the mining or stockpiling of ore grade materials, especially in any bulk quantities that necessitated the oversight of the CNSC.
- also recommended the term Abandonment License be removed, as release from licensing, like Cluff Lake, is the right path forward.

Will items like the above be addressed in this proposed RegDoc, and if so please identify where.

I grew up on a nuclear waste site for my first 9 years, and for 25 years after that I lived near the Pickering Nuclear Power Plant.  I was so happy to finally get away from that.  But I still do not know what impact it has on my health.  I feel bad for my parents who still live there, and for all the people and animals who have to live near radiation pollution.  I am quite concerned with 3.9.8, which mandates testing “fish tissue and other receptor species tests for exposure uptake”.  As Canada is moving away from animal testing, this seems counterintuitive to include animal testing in a document to modernize practices, especially when there is no mention of phasing out and replacing the practice.  Mining is harmful to all life, and to the planet.  Forcing fish and birds to be exposed to the effluent, and cutting them up to test them for selenium and other pollutants is cruel and outdated.  Canada is phasing out toxicity testing on animals.  Please switch to animal free methods of testing effluent and other substances.  For wild fish and birds, please stop lethal sampling and switch to humane non lethal bio monitoring like is done in humans. 

Mines destroy all sorts of animals in laboratory testing of their effluents, and in lethal sampling of birds, fish, frogs, etc.  Please do not use animal testing for pollution monitoring. 

There are cruelty free modern alternatives to animal testing, including acute lethality testing.  Cell cultures can determine effect of pollution for instance.  Please reach out to antivivisection organizations regarding these tests, and lobby to change these outdated laws.

Please stop the “acute lethality tests” on rainbow trout, three lined stickleback, and other fish species.  These tests involve pumping effluents into fish tanks about once a month, and if more than half the fish die, the experiments are repeated.  There are animal free ways to test for pollution.  Any guardians of companion fish will test their tank using paper strips and test tubes. They do not deliberately expose the fish to effluents to see what happens.  Please also end the practice of sublethal toxicity testing of effluent on baby fathead minnows and rainbow trout, and stop cutting up fish to test their livers for mercury.  Please lobby the government to put an end to mandatory toxicity testing under the Fisheries Act and go cruelty free.  Please only use non lethal sampling of wild fish, or take tissue samples from fish who were already caught for human consumption.  Please do not kill or harm any animals for research.  

Many mining companies also kill animals as “pests”.  Please only use non lethal methods of wildlife coexistence.   

Please only use humane non lethal methods to manage beavers and other wildlife.  Killing beavers only leaves room for more animals to move in.  And the traps kill many other animals.  London Ontario and many other places manage beavers without killing.