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The CNSC’s misinterpretation of the contract resulted in the CNSC determining that uranium mine waste rock at the three properties falls outside of its jurisdiction and the application of the !‘/SCA. [...] The purpose of the NSCA is to limit, to a reasonable level and in a manner that is consistent with Canada’s intemational obligations, the risks to the health and safety of persons and the environment that are associated with the development, production and use of nuclear energy and the production, possession and use of nuclear substances. [...] CNSC’s interpretation of s.10 is unreasonable because it is not consistent with the text of section 10 of the General Regulations, the text of the General Regulations, the NSCA and other related regulations, CNSC’s regulatory guidance documents, or the purpose and context of the NSCA regime. [...] To the contrary, the evidence submitted by the Applicants and included with the CNSC’s decision shows that the preferred remedial option for was removal of the uranium mine waste rock from the property, but that has not occurred. [...] Pursuant to Rules 317 and 318 of the Federal Courts Rules, the Applicants request that the Canadian Nuclear Safety Commission send a certified copy of the tribunal record, which is not in the possession of the Applicants but is in the possession of the Canadian Nuclear Safety Commission, to the Applicants and to the Federal Court Registry.