Section 24(4)(b) of the NSCA CELA also submits that the proponent CNL has not demonstrated that it will “make adequate provision for the protection of the environment, the health and safety of persons and the maintenance of national security and measures required to implement international obligations to which Canada has agreed” as required under section 24(4)(b) of the NSCA for the following reas. [...] This would mean in the case of the proposed NSDF, that the waste must be retrievable, for example in the event that the system does not perform as expected, or a future finding that some type of waste emplaced in the NSDF must not be left in place. [...] CELA submits this is contrary to the purposes of CEAA 2012 and the objects of the Nuclear Safety Control Act, which require the CNSC to exercise their powers in a manner that protects human health.9 CELA submits that the Environmental Assessment, inclusive of evidence presented at the hearing, fails to provide any acceptable justification for the exposures to workers and the public that are predic. [...] c) The Panel should find that the Proponent will not make adequate provision for the protection of the environment, the health and safety of persons and the maintenance of national security and measures required to implement international obligations to which Canada has agreed d) The Panel should find that the application lacks essential information, which is mandatory before a licence may be issu. [...] g) The Panel should find that there is no basis on which the it can conclude that the needs of future generations (such as for safety and protection of the environment) will be protected by the project; in particular because of the failure to satisfy the requirement of sustainability through the failure of the proponent to plan for retrievability of waste in case of accident, malfunction, or for o.
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