Panel Report

In August, 1991, the governments of Canada and Saskatchewan appointed a joint federal-provincial environmental assessment panel to review several proposed uranium mining developments in northern Saskatchewan. Part of the mandate given to the joint panel at that time was a requirement to review the cumulative impacts of existing operations and proposed developments. This report is submitted in response to that requirement. The primary conclusions, summarized in Chapter 7, are based on our accumulated knowledge of the entire industry, as differentiated from the individual projects that have been dealt with in separate reports.

Because it is the people living in northern Saskatchewan who will experience the greatest impacts of these projects, we have paid particular attention to their concerns. After listening carefully, reading widely, and debating at length, we have concluded that the best course is to recommend that the mines be allowed to proceed under conditions that would limit environmental damage and enhance northern benefits. In other reports, we have tried to achieve this objective by making project-specific recommendations; in this report, we wish to comment on several general issues that would have an impact on the potential benefits from these projects.

1. Education is a key component. Without a continuation of initiatives such as the Multi-Party Training Plan, northerners will not be able to share in the opportunities offered by the uranium mining industry.
2. Employment and business opportunities must be made available to northerners. This is most effectively accomplished by including appropriate objectives in the Human Resources Agreements that are attached to the surface leases for the mines.
3. Protection of northern communities and the people in them is as important as protection of the biota. Qualified professionals should be engaged to monitor and study the impacts of uranium mining on the quality of life in northern communities. Any detrimental impacts should be mitigated.
4. Scientific research can suggest approaches that will improve the profitability of the industry, while at the same time providing greater environmental protection. Governments, in cooperation with the industry, should promote such research at the Saskatchewan Research Council and the universities.
5. Centralized milling of the ore from several mines at one location will cause less environmental damage, in total, than milling at a series of sites near the mines. Collective milling of several ores should, therefore, be encouraged.
6. In-pit tailings disposal facilities provide better environmental protection than do aboveground facilities. We recommend, therefore, that in the future all tailings should be placed in mined-out pits.
7. All mine rock wastes that have the potential to be acid-generating should be protected from oxygen exposure. This can be achieved by using them for fill when underground mines are decommissioned or by placement in mined-out pits. Underwater disposal in existing lakes should be an option that is considered only if no suitable mined-out pits are available.
8. Perpetual monitoring of decommissioned tailings management facilities and potential acid-generating waste rock depositories will be necessary. A self-sustaining fund should be designated for the cost of monitoring and any mitigation required.
9. Cumulative effects monitoring is necessary on a regional scale to assess the potential spread of contaminants from these mines. It is important that adequate funding continues to be provided to the Cumulative Effects Monitoring Working Group (CEMWG).
10. The Environmental Quality Committees provide northerners with vehicles through which they can participate in the development of this industry. Providing northern people with a better understanding of this industry and empowering them to participate in its future developments is the best way to protect the northern environment. Governments and the industry should continue to support the EQCs.
11. The Province should complete a comprehensive study of the cumulative demands that will be placed on northern roads in the future and prepare, in cooperation with the users, to maintain them at acceptable standards.
12. Mine workers, particularly those in underground developments, depend on mine regulators to ensure safe workplaces. It is, therefore, essential that legislation and regulations provide adequate protection for both contract and non-contract workers; that mine sites be inspected frequently; and that due care be exercised to ensure that safe work practices are being followed.

Since the panel was created in 1991, it has conducted public reviews of a total of seven environmental impact statements (McArthur River Underground Exploration, Dominique-Janine Extension, Midwest Joint Venture, McClean Lake Project, McArthur River Project, Cigar Lake Project and Midwest Project). Included in the reviews have been the mining of nine ore bodies, the construction of one mill, the design of two tailings management facilities and the expansion of the transportation system. In completing our work, we have read 42,586 pages of information provided by the proponents; received and read 587 written sub-missions; listened to and made notes on 764 verbal presentations; generated 10,485 pages of transcripts; commissioned nine technical reports; issued nine requests for additional information; and, written six reports, including this one. During that time, we have spent 84 days in public hearings and participated in 39 panel meetings, as well as an untotalled number of conference calls. Altogether the panel has spent 62 days in northern Saskatchewan, more it is believed, than any other panel or commission of its kind.

During all of this work, we have been received hospitably and treated with respect by all, including members of the public, representatives of various interest groups, the proponents, the industry regulators and officials from local, tribal, provincial and federal governments. We have met an astonishing array of people, each with her or his individual perspective on the uranium mining industry. Our work has been both enlightening and arduous, and we are profoundly grateful to everyone who has contributed to our understanding of these projects and their potential impacts on the environment and people of northern Saskatchewan. We are especially grateful to two former panel members, Annalee Yassi and John Dantouze, who made outstanding contributions to the reviews before their resignations and for the assistance of our secretariat, Bob Greyell, Guy Riverin, Henry Epp, Heather Humphries, Don Hovdebo and Jackie Kelly.

Throughout all of this activity, our appreciation for and understanding of the industry under review has increased, as has our respect for the potential environmental damage that could be unleashed on northern Saskatchewan if the projects were not properly developed. In response to that section in our terms of reference which requires us to examine the cumulative effects of these projects, we have included this summary report on the combined impacts of the various mines, mills and roads. The recommendations and conclusions contained herein are based on our accumulated knowledge of the entire industry, as differentiated from the individual projects that have been dealt with in separate reports. Responses by the governments of Saskatchewan and Canada to these recommendations could, therefore, be made separately from their responses to the recommendations on the Midwest and Cigar Lake projects which are being submitted simultaneously.

These comments have been organized under headings derived from our terms of reference -- environmental issues, safety concerns, health implications and socio-economic impacts.

The primary focus of these reviews has been the environment of northern Saskatchewan and its preservation for future generations.

The mines are located in a part of Canada that is largely undeveloped and free of the negative impacts that industrial development often brings to a geographical area. Such an environment is often more vulnerable and more valuable than others that have already been impacted by industry. Preservation of a pristine environment is preferable in every way to restoration of an environment that has been allowed to deteriorate.

The importance of the environment to the residents of northern Saskatchewan was clearly drawn to our attention very early in the review by Maureen Ahenakew:

The earth gives us our sustenance. Our survival, our lives depend on the purity and the cleanliness of the earth. In my mind it's so clear, and there is no confusion, or, I guess, it can't be said any more simpler than to say that we are risking the lives of everyone by continuing with any kind of mining or any kind of destruction of the earth. I see uranium mining as being just that--destruction of the earth. In a common sense thinking, you think of it as destruction of the earth means immediate economics. Economics are not going to do us any good. Money is not going to do us any good, if there is no life. It has no value. We all need water, we all need food and we all need to eat, we all need to drink. We all need to breathe air in order to survive--all of us. It does not matter what colour we are or which part of the world we live in, we all need all of those things to survive. If they are poisoned, then we are poisoned. We see it now. [Maureen Ahenakew, Transcript of Public Hearings on the McArthur River Underground Exploration Program , Saskatoon, Saskatchewan, December 4-5, 1992, p. 71.]

Others, such as John James Mercredi, were less convinced of mining's negative impacts on the northern environment:

The issue that we're talking about here, we're talking about mining activity in northern Saskatchewan. And some people are instigating, I guess they were saying, that mining destroys the environment. I would like to see some proof of that because like I said, worked in the mining industry myself. And when it comes to a disruption in the land and disruption in the environment as well as wildlife, I'd like to see some concrete evidence. I need to see more of that. I need to hear that from the people here as well too. So just a bit of a challenge, I guess you can say, with regards to changes in the environment that you have seen because of this mining activity. You know, I have to hear from people who have witnessed it. [John James Mercredi, Transcript of Public Hearings on the McClean Lake Project, Midwest Joint Venture Ltd., and Dominique-Janine Extension at Cluff Lake , Black Lake, Saskatchewan, April 13, 1993, pp. 103-104.]

Still others supported mining on the understanding that it would be done in cooperation with northern people and that northern residents would be guaranteed a majority share of the employment opportunities. Facing the proponents one evening in Black Lake, the elder, Louis Chicken, had this to say:

So when I talk about our people today, we're very poor. I know that. And I'm asking for opportunities for my future generations. And when we talk about these types of things, and as I've always done, I will always continue to do that I guess. You're saying that you're creating opportunities for us today. And we need guarantees. Because in the past I don't think we've had opportunities like that where we were given options, I guess. And right now I think that the direction that things are going with opportunities that you're talking about creating, is the way to go.

Because at least we will be given chances, I guess you can say, to better our lives if we could be party to those jobs that you are talking about creating. So I think helping each other and dealing with each other, face to face, is the way to go. Like I said already, I don't speak for myself. And I speak for a lot of the young people who are watching here today. And when elders speak, they try and provide the best information they can for people around them.

And like I've always done in my past practices as a political leader for my people, I try and deal with these issues head on. And deal with them person to person to resolve it. And if you could reach an agreement where these jobs that you're promising would be protected, would be the way to go. Thank you. [Senator Louis Chicken, Transcript of Public Hearings on the McClean Lake Project, Midwest Joint Venture Ltd., Dominique-Janine Extension at Cluff Lake , Black Lake, Saskatchewan, April 13, 1993, p. 145.]

After listening carefully, reading widely, and debating at length, we have concluded that the best course is to recommend that the mines be allowed to proceed under conditions that would minimize environmental damage and maximize northern benefits.

We are aware that the environment can recover from most of the immediate impacts of mining. Over time, the terrestrial disturbances that occur when the mine sites and roads are constructed will become revegetated and habitable by birds, animals and people. Over time, the lakes and streams will be cleansed of contaminants that are released in the mine effluent, provided that regulatory limits are observed. Over time, atmospheric pollutants will be dispersed until they are negligible compared to background levels. Such environmental impacts, we concluded, could be tolerated in the interest of providing northern people with economic opportunities.

There are, however, other long-lasting impacts associated with the disposal of waste rock and tailings with which nature may not be able to cope.

We are very concerned about the potential continuing environmental damage that could result from acid mine rock drainage. There are no natural processes, of which we are aware, that would serve to mitigate acid mine rock drainage in northern Saskatchewan. If allowed to occur, it would destroy habitat and impact negatively on the environment for as long as it is possible to foresee.

Tailings management facilities have an even greater potential for contamination of the ground water over the long term. If the disposal pits currently being considered fail to function as expected, and if mitigative measures are not at hand, extensive pollution could occur.

It is these two long-term threats to the environment, and their need for monitoring, that are the subjects of the remainder of this section. It is essential that future generations not be left with problems that cost more to mitigate than the current generation derives in benefits.

2.1 Disposal of Mine Waste Rock

It is usually necessary to remove large volumes of overburden to gain access to an ore-bearing deposit. This non-ore-bearing rock, which miners refer to as waste, may be considered to be clean if it contains no soluble heavy metals or minerals that can be oxidized by atmospheric oxygen. Some clean waste can be used as construction aggregate, thereby providing a measure of value-added benefit from mine waste materials. Unfortunately, not all clean waste rock materials can be disposed of in such a beneficial fashion; some must be permanently deposited on the surface of the earth. Such waste piles, if properly contoured and vegetated, cause an altered landscape, but little or no environmental damage. A good example of a well-contoured and revegetated waste pile may be observed at the Cluff Lake site where hydroseeding has been used to accelerate revege-tation.

Precipitation will flush readily soluble contaminants from waste piles containing mineralized wastes (sometimes called special wastes). In Saskatchewan uranium mines, the principal contaminants are uranium-derived radionuclides and heavy metals (particularly arsenic and nickel, and to a lesser extent copper, zinc, cadmium, molybdenum and iron). If the waste also contains sulphide minerals, exposure to oxygen and water results in the formation of acids which accelerate the release of heavy metals and radionuclides from the waste pile. [L.M. Broughton, R.W. Chambers and A. MacG. Robertson, Mine Rock Guidelines, Design and Control of Drainage Water Quality , Saskatchewan Environment and Public Safety, April, 1992, Chapter 3.] The impact of this acid mine rock drainage is to pollute the drainage area in the immediate vicinity of the waste pile and downstream in decreasing concentrations. For this reason, mineral-containing wastes cannot be placed in surface waste piles; they must, instead, be disposed of in a way that eliminates or greatly reduces exposure to atmospheric oxygen. Research has indicated that the two best ways of doing this are to return the waste underground where reducing conditions prevail or to store it under a cover of water. [Ibid, Chapter 6.]

Current research into the understanding and mitigation of the release of contaminants from waste rock is well advanced. Uranium mines in Saskatchewan have participated in the Mine Environment Neutralization Drainage (MEND) program by providing sponsorship of workshops on the development of water cover technologies. Such participation in the development of new technologies for mitigating impacts associated with waste rock disposal indicates the high level of concern exhibited by the various proponents. They are also to be commended for their initiatives to replace maximum quantities of mine waste rock either underground or into open pit excavations.

The methods proposed for handling waste rock at the Midwest and Cigar Lake projects provide examples of the major difficulties that may be encountered. For the Midwest Project, Cogema proposed that a quantity of inert waste rock, approximating 110,000 tonnes, be abandoned at a site adjacent to the underground mine, on the west shore of Mink Arm. [The Midwest Project Environmental Impact Statement, Main Document , Cogema Resources Inc., August, 1995, pp. 2-47.] This waste pile would represent a new topographical feature along Mink Arm that might cause some change in drainage patterns. Such an impact would be acceptable if it were not for the possibility that the imperfect separation of clean and special waste might result in acid mine rock drainage into Mink Arm. In general, there is a concern about the proponents' ability to separate clean and potentially acid-generating waste rock.

Classification of waste as clean or special is based on the results of advance drilling and subsequent laboratory testing of the samples from that drilling. [The McArthur River Project Environmental Impact Statement, Addendum , Cameco Corporation, June, 1996, p. 2.1.13.] Although the mining companies express confidence in this procedure, the fact that there is no way to assess the acid-generating potential of the waste rock in each truckload emerging from the mine leaves concern in the minds of some members of the public. In our opinion, there is a need to find more precise methods for distinguishing between potential acid-generating waste and non-acid-generating waste as excavation proceeds. Research directed toward the development of such methods could prove to be a good investment.

At Cigar Lake, the proponents face a different problem. There, very little of the waste rock is clean and a way must be found to safely dispose of 2.6 million tonnes (1.35 million cubic metres) [The Cigar Lake Project Environmental Impact Statement, Main Document , Cigar Lake Mining Corporation, July, 1995, p. 3-99 and Table 3.6.31.] of potentially acid-generating rock. To accomplish this, the proponent proposed underwater storage, first at Bizarre Lake and, later, at Lake 497 when it was discovered that Bizarre Lake provided valuable fish habitat. However, a representative from the Department of Fisheries and Oceans cautioned that, "Granting approval for this disposal of potentially acid generating waste rock into a lake inhabited by fishes would be precedent-setting for northern Saskatchewan," [B. Fallis, Transcript of Public Hearings for the McArthur River and Cigar Lake Projects , Saskatoon, Saskatchewan, September 18, 1996, p. 148.] and Environment Canada recommended that consideration should be given to the possibility of disposing of the mine rock wastes in one of the mined-out pits at the nearby McClean Lake site. [Environment Canada, Technical Position on the Cigar Lake Uranium Project , September, 1996, p. 11.]

Both solutions, lake and pit disposal, contain future uncertainties that could result in environmental damage. It appears that waste rock disposal in Lake 497 would not cause an unacceptable loss of fish habitat; however, it is possible that future conditions, as yet unrecognized, could cause the water level to drop, exposing the wastes to atmospheric oxygen. On the other hand, the pits at McClean Lake have yet to be completely excavated and the hydrogeology there may make them unsuitable for waste rock deposition. Furthermore, it is expected that the Sue pits may not be fully excavated by the time Cigar Lake starts production, thereby requiring the storage of waste rock on surface in contact with atmospheric oxygen for several years before deposition could begin. By the time that deposition could begin, the acid-generating processes would be well established in the stockpile.

As can be seen from these examples, none of the choices for waste rock disposal can be made with complete assurance that all future impacts will be acceptable. In principle, however, we do not favour the use of lakes as waste depositories if other acceptable options are available. Philosophically, it does not seem that the use of a lake for waste disposal is compatible with environmental preservation, especially if there are mined-out pits nearby. We are in general agreement with the stated position of Environment Canada:

Subsurface disposal of all tailings, special waste and waste rock would appear to mitigate all potential long-term environmental problems at surface waste piles and flooded pits. This is Environment Canada's preferred option for the disposal of all solid wastes from new Saskatchewan mines. [Environment Canada, Technical Evaluation of the Environmental Impact Statement, Midwest Uranium Project , August, 1995, p. 20.]

Ideally, pits that are used for waste depositories should be completely filled and capped with several metres of clean waste and till to avoid the formation of water ponds in the top of the pit. Over time, contaminants may diffuse upward from the wastes into such ponds, presenting a health hazard to people or animals who drink the water.

2.2 Milling and Tailings Management Facilities

2.2.1 The Milling Process

The milling of the ore derived from uranium mines is a well understood and widely used operation. Although the chemistry of the milling process is somewhat complex, [The Cigar Lake Project Environmental Impact Statement, Response to Request for Additional Information on the Cigar Lake Project, Cigar Lake Mining Corporation, March, 1996, p. 4-1.] the essential steps are:

• crushing of the mine rock to expose the uranium minerals to the action of chemical reagents;
• oxidation of all uranium present to yield dioxouranium (VI), UO₂⁺⁺;
• calcination of the precipitate to yield yellow cake, U₃O₈;
• neutralization of the tailings; and
• deposition of tailings in the tailings management facility.

For certain ores, other metals such as nickel, cobalt or molybdenum are also extracted in separate operations.

Although these processes have been successfully used for many years, it is apparent that improvements are still possible. For example, when the Province of Saskatchewan required Cogema to conduct research into ways to reduce process chemicals as part of the approval of the McClean Lake mill, [The Government's Position on Proposed Uranium Mining Developments in Northern Saskatchewan, Province of Saskatchewan, December, 1993.] it was found possible to make changes that resulted in a 28-per cent reduction in the volume of tailings discharged. [The Midwest Project Environmental Impact Statement, Main Document, Cogema Resources Inc., August, 1995, p. 3-4.] There seems little doubt that a sustained program of research would result in further efficiencies with respect to the amount of chemicals used and the toxicity of the tailings produced. Considering the vast reserves of uranium already known in northern Saskatchewan and the potential for the discovery of additional deposits, there is every indication that uranium mining will continue for several decades and that an applied research program would be a good investment. We are, therefore, recommending that the province, in cooperation with the industry, take measures to promote a continuing scientific search for ways to improve the milling process.

2.2.2 Liquid Effluent

Milling produces contaminated water that must be treated before release into the environment. Other sources of liquid effluent that also require treatment include mine water and pore water expressed from the tailings. The treatment process is designed primarily to decrease the concentration of radio-nuclides and toxic heavy metals in the effluent by addition of chemical reagents that form precipitates with metal ions. For example, radium is removed by addition of barium chloride to produce a coprecipitate of barium sulphate and radium sulphate. This process decreases the concentrations of radionuclides such as radium and other heavy metals, but results in an increase in the concentration of soluble salts (primarily chlorides and sulphates) in solution.

Water treatment, therefore, involves an environmental trade-off, whereby the mitigation of one problem (containment of heavy metals and radionuclides) creates or exacerbates another problem (increased salinity). The environmental impact of increased salinity is acceptable for two reasons: it is less harmful than elevated concentrations of radionuclides and heavy metals; and, the salinity change in the receiving waters is not permanent. After decommissioning, when water treatment stops, the salt concentration will drop to background levels and any organisms that have been eliminated because of the change in salinity can reinvade and become re-established.

Precipitation processes reduce the concentration of radionuclides and heavy metals but do not completely remove them from the effluent. Therefore, the total environmental loading of these contaminants can still be considerable if sufficiently large volumes of effluent are released. Even though the concentrations of radionuclides and metals are very low, the large volume of effluent means that surprisingly large amounts of these elements are released. For example, the Department of Fisheries and Oceans has calculated that 103,230 kg of uranium would be released in treated effluent discharged from the McClean Lake project. [Position and Technical Review of the Response to the Uranium Mines Review Panel Request for Additional Information concerning the Complementary McClean Lake and Midwest Projects, McClean Lake Project, Department of Fisheries and Oceans, Central and Arctic Region, Submission to Panel, March, 1993.]

The spread of radionuclides and metals can be limited if they are absorbed by the sediments and suspended particulate matter. Contaminants will spread less if the effluent is released into a bog or lake where the water is in contact with organic sediments for a long period, than if released into a river or lake with a larger turnover rate.

The two problems posed by liquid effluent are antagonistic; a decrease in the one (salinity) leads to an increase in the other (total environmental loading of radionuclides and heavy metals). Moveover, they are resolved in incompatible ways. In the first case, the effluent should be diluted as rapidly as possible to flush the salts from the system; in the second, the aim is to confine the effluent for as long as possible to allow time for contaminants to be adsorbed from solution.

One procedure that is compatible with both problems is the reduction of the volume of effluent by decreasing mine-water inflow and by recycling water in the milling process as much as possible. A second compatible resolution is the removal of radionuclides and metals from the contaminated water by other processes, such as adsorption onto organic particles or ion exchange columns. Both of these possibilities merit further research.

We wish to reiterate three recommendations that we have previously made with respect to the release of liquid effluent. First, a research program should be established to search for innovative ways to reduce the volume of effluent and the quantity of chemicals required to treat contaminated water. The objectives should be a zero-effluent mill and minimal liquid effluent from other mining operations.

Second, site-specific surface water quality objectives, appropriate for the Athabasca region, rather than for Saskatchewan as a whole, should be developed. The present Saskatchewan Surface Water Quality Objectives (SSWQO), applicable for southern Saskatchewan where there is often a high concentration of total dissolved solids (TDS) in the water, are not always appropriate for the Athabasca region. In addition, the new objectives should include a uranium water quality guideline for aquatic biota, and guidelines for any other significant ions or elements which are presently excluded.

Third, the total environmental loading should be specified for all contaminants. Each mine should be required to develop a material-balance for all contaminants released in its effluent. Through their monitoring programs, the individual mines should be able to account for the spread of their contaminants in the watershed, and SERM should compile a cumulative record based on the individual reports. The spread of contaminants on a regional scale would be monitored by the CEMWG (see Section 2.4). It is essential that an improved understanding of the spread of these contaminants throughout the environment be obtained.

2.2.3 Tailings

The composition of tailings produced from the milling of uranium ore will be determined by the process chemicals added and the mineralogy of the ore. For example, if the ore being milled contains a high concentration of arsenic or some other toxic metal, the tailings will also contain high concentrations of those same metals. Moreover, the metals in the tailings will be in chemical forms that are more soluble and consequently more mobile than they were in the original ore body. This is so because constituents of undisturbed ore will have attained an equilibrium in which the metals have combined with other elements to form insoluble minerals; however, the milling process, which involves grinding of the ore and oxidation of the exposed minerals, produces metallic elements in more soluble forms.

Many of the heavy metals displaced from their equilibrium states in this way are toxic and some are radioactive. For this reason, it is necessary to ensure that they are not released to the environment where they could cause widespread contamination of the surface and/or ground water. Because it will take a very long time for them to return to an equilibrium state in which they are insoluble and consequently immobile, it is necessary to provide containment measures that will last indefinitely.

The need to provide containment in perpetuity suggests that the use of engineered structures is not likely to be satisfactory. Attempts to contain tailings behind an engineered dam, for example, might result in environmental problems for succeeding generations if the dam fails at some distant time. Since there are very few engineered structures that have endured for the length of time required for tailings containment, it appears intuitively more acceptable to use natural barriers that would undergo change only on a geologic time scale. It is primarily for this reason that all of the most recently planned tailings management facilities (Rabbit Lake, Key Lake and McClean Lake) have used mined-out pits where the physical barriers are rock formations that have been in place for eons. [Opportunity North, Northern Mines Monitoring Secretariat Supplement, Vol. 4, No. 3, 1997.]

Subsurface placement of the tailings with an adequate cover eliminates the possibility of contact with the biota on the surface of the earth in the short term. However, possible long-term contamination by migration of toxic and/or radioactive metals through the ground water is of greater concern. The operators of all of the existing or proposed tailings disposal pits have provided modelling studies that indicate the tailings, in most cases, will consolidate to form an impervious plug and that migration of contaminants will be slow. We sincerely hope that the modelling exercises prove to be fairly accurate; however, experience has taught that it is wise not to confuse modelling studies with reality and we have, therefore, recommended that the performance of these facilities be carefully monitored to ensure that consolidation is occurring and that contaminant migration is below acceptable limits. Furthermore, realistic mitigation measures for any likely problem with the system should be identified prior to the start of tailings deposition.

On the basis of our current understanding of tailings management facilities, we have concluded that sub-surface deposition is preferred to the use of above-ground facilities and that, wherever it is feasible, tailings currently stored aboveground should be placed below the surface of the ground. We are also in agreement with the current practice of using one mill and one tailings disposal facility for several mines. The complexity of long-term monitoring and maintenance will be directly related to the number of tailings disposal sites in existence. Great care should be taken when a site for subsurface disposal is selected; it is usually better to choose a site after the pit has been completely mined out and the geology and hydrogeology of the surrounding formations have been thoroughly studied.

Our most urgent recommendation with respect to tailings management facilities is that they be carefully monitored from the very beginning and that a monitoring regime which will endure indefinitely be established for all of the tailings management sites in northern Saskatchewan. Since in-pit tailings technology cannot be considered to be fully proven until it has been shown that the tailings are consolidating and that the rate of migration of contaminants is low, it will not be possible to satisfactorily evaluate the performance of these facilities for several decades. Until that time, the owners should be responsible for the cost of any required mitigative measures. Beyond that time, the Province should undertake to provide continuing monitoring and mitigation, if necessary.

For this reason, the panel has recommended the establishment of a contingency fund to provide for the on-going costs of long-term monitoring (and mitigation, should it be required) after the responsibility for the sites have been returned to the Province. [D.G. Lee, J.F. Archibald and R. Neal, McArthur River Uranium Mine Project, Supply and Services Canada, February, 1997, p. 48.] An industry-wide fund would provide better overall fiscal protection to future generations and cost less, in total, than individual funds for each site. There could also be a single authority to manage the fund and oversee the maintenance, monitoring and mitigation activities at all decommissioned uranium mine and mill sites. It is anticipated that the authority would be located in northern Saskatchewan and employ primarily residents of Saskatchewan's north.

2.3 Decommissioning

Saskatchewan has been a major uranium producer since 1953. The first twenty years of mining production occurred on the north shore of Lake Athabasca in the area around Uranium City; three mills -- Gunnar, Lorado, and Eldorado -- operated in that region. During the mid-1970s, uranium mining moved further south into the Athabasca Basin to the sites which are still operating at Cluff, Key and Rabbit Lakes. More recently, new mines have been approved at McArthur River and McClean Lake.

To date, no uranium mining operation in northern Saskatchewan has been completely decommissioned. Although initial work was done at the Eldorado site in the early 1980s, decommissioning efforts continue to this day in an attempt to mitigate concerns with the tailings management area. The length of time required to complete the Eldorado decommissioning is understandable in terms of its history; the mine started operations in the mid-1950s, when there was little concern for, or knowledge about, the design of tailings management areas that provided environmental protection or long-term containment.

The other two mining and milling operations on the north shore of Lake Athabasca, Gunnar and Lorado, were privately owned and no site decommissioning or reclamation took place when the owners ceased operations in the mid-1960s. As a result, each site continues to discharge varying levels of contaminants to the environment. In addition, all of the Gunnar site buildings were left intact and have deteriorated to the extent that they are also a safety hazard.

A question frequently raised in public hearings, particularly by northerners, regarded the ability or willingness of operators to successfully decommission existing mines and any new mines that might receive approval. To date, neither industry nor government has demonstrated a strong commitment to decommissioning abandoned uranium mining sites.

Over the past four years, the Governments of Canada and Saskatchewan have approved an increase in uranium production from which both will accrue substantial benefits. It would, therefore, be appropriate for the federal and provincial governments to address the environmental legacy of uranium mining by working cooperatively to ensure the full decommissioning of all abandoned uranium mine sites and tailings disposal areas in Saskatchewan.

2.3.1 Financial Guarantees

During hearings held in 1993, the public made it clear that decommissioning costs should be the financial responsibility of the mining companies and not of the government; i.e. the taxpayers. The public's strong conviction on this issue stems from the way in which mines near Uranium City were abandoned when no longer profitable, with the costs of decommissioning and reclamation left to the public purse.

In our October, 1993 report, we recommended "that a financial guarantee to cover the cost of decommissioning and post-decommissioning costs of a project be secured from the proponent before the project is approved". [D.G. Lee, J.F. Archibald, J. Dantouze, R. Neal, A. Yassi, Dominique-Janine Extension, McClean Lake Project, and Midwest Joint Venture, Supply and Services Canada, October, 1993, p. 15.] In 1996, during hearings on a subsequent proposal, we were informed that, in Saskatchewan, the requirement to provide such a guarantee became law on March 5, 1996, as part of changes to the Mineral Industry Environmental Protection Regulations and that the Atomic Energy Control Board (AECB) had accomplished the same objective by an amendment to the Uranium and Thorium Mining Regulations.

These changes to both federal and provincial regulations pertaining to uranium mining decommissioning provide a measure of protection for the tax-paying public

2.3.2 Uranium Mining Contingency Fund

Throughout the public hearings on all seven proposals, presenters were insistent that, because of the continuing toxicity of many of the contaminants, the mine and tailings sites should be monitored long after operations have ceased. We agree with that concern. We believe that a dedicated and self-sustaining fund would be the best way to finance postdecommissioning monitoring and to cover the cost of any mitigation that might be required.

We first recommended such a fund in the McArthur River report noting that the Deilmann Tailings Management Facility, in particular, would require long-term monitoring and possible mitigation in the future.

In its response to this recommendation, the Government of Saskatchewan stated:

Recognizing its responsibility for long-term management of the site, the Province is investigating options, including a contingency fund as proposed by the Panel, for implementation of monitoring and the funding of possible mitigation should it be required. [The Government's Position on Proposed Uranium Developments in Northern Saskatchewan, McArthur River Project, Government of Saskatchewan, May, 1997, p. 21.]

The recommendation for a contingency fund, reiterated in the Midwest and Cigar Lake reports, is repeated here. It would be more appropriate to establish this fund in response to cumulative concern about decommissioning costs, rather than in response to concern about a single uranium mining project. The government is encouraged to establish the Uranium Mining Contingency Fund as quickly as possible.

2.3.3 Ongoing Research

The mining regulations administered by both the federal and provincial governments require that a site-specific conceptual decommissioning plan be prepared by the proponent. This plan, which includes proposed reclamation activities and associated costs, must be submitted, reviewed and approved prior to the issuance of an approval to operate a mine. The conceptual plans are judged to be acceptable if the sites can be decommissioned using existing technology.

Proponents and regulators must not be complacent with existing technology; research efforts must continue, focusing on advancing decommissioning technology in an effort to minimize the environmental footprint left by mining and milling activities. It is imperative that every effort be made to return disturbed areas to as near to premining conditions as possible and to ensure that the sites are physically and chemically stable over the long term.

2.3.4 Local Involvement

During public hearings, it was also evident that members of the public, particularly northern residents, feel the need for local communities to be consulted on both the conceptual and final decommissioning plans. Since it will be their descendants who will have the decommissioned sites in their backyards, it is important that they be involved not only in developing the plans, but also in implementing the decommissioning, reclamation and postdecommissioning monitoring. The Environmental Quality Committees provide an ideal vehicle through which local people can be consulted on decommissioning issues, activities and monitoring.

2.4 Monitoring and Mitigation

The commitment of the proponents to monitoring the concentration of contaminants in the abiotic components of air, water, soil and sediments is in sharp contrast to their apparent resistance to monitoring biological effects. They accept the appropriateness of monitoring the release of contaminants and their concentrations in certain organisms such as fish; they do not acknowledge a need for concern about the effects of these contaminants on the biota in the areas surrounding the mines. For example, in its response to the McArthur River report, the proponent argued against doing biological effects monitoring because Cameco's risk assessment had concluded that there would be little effect on organisms. [Cameco Corporation, McArthur River Project, Response to the Report of the Joint Federal-Provincial Panel, April, 1997, p. 19.] Cameco's position is untenable; the limitations of an impact assessment approach relying only on risk assessment were directly addressed in the panel's report. [D.G. Lee, J.F. Archibald and R.Neal, McArthur River Uranium Mine Project, Supply and Services Canada, February, 1997, p. 36.] Consider an analogous situation, the analysis of radiation risks to workers in the mine and mill. Cameco has concluded that the health risk to workers is very small, but it does not advocate that, as a consequence, there is no need to monitor worker health.

We have recommended the expansion of biological effects monitoring to include, at all mine sites, all of the Valued Ecosystem Components that are monitored for cumulative effects at more distant sites. In addition, we recommend that the technical group that advises on monitoring protocols be broadened to include appropriate expertise from universities and from government institutes. This technical group should hold regular workshops, open to the public and to the Environmental Quality Committees, to review and advise on biological effects monitoring for uranium mines. These recommendations have been endorsed by many northern residents, including representatives of the Environmental Quality Committees.

Throughout the public hearing process, one of the overwhelming public concerns has been that uranium mining might pollute the water and biota around the mine sites irreversibly. People are not reassured by risk analyses and modelling predicting that their fears are groundless; they demand that the mining companies prove that contaminants are being successfully contained and not damaging the surrounding ecosystems. This can only be achieved with monitoring programs that are carefully designed and implemented with the involvement of local people.

In response to a 1993 panel recommendation, Saskatchewan Environment and Resource Management and the Atomic Energy Control Board developed a cumulative effects monitoring program in 1994 to examine the regional impacts of uranium mining on the environment. We are encouraged by this initiative and note their establishment of a Cumulative Effects Monitoring Working Group (CEMWG), including a wide range of expert opinion, and subsequent involvement of local residents in helping to sample some of the biota. We would encourage further attempts to give northerners a sense of partnership in the monitoring program and its results.

In addition, we recommend that detailed sediment cores be collected at certain key sites (e.g. at the exits from Wollaston Lake to the Fond du Lac and Cochrane river systems) to provide a history of the flux of contaminants in the region. Such sampling would provide an accurate assessment of the regional spread, if any, of contaminants from the mines.

We also recommend perpetual monitoring for tailings disposal facilities (Section 2.2.3) and for waste rock with acid-generating potential.

The panel's choice of the word, perpetual, was debated during public hearings; the panel's intent requires clarification. Two factors must be recognized when determining the length of time required here for monitoring. First, the containment of contaminants will depend on the structural integrity of engineered solutions being maintained for tens of thousands of years, much longer than all of recorded human history. Where such wastes are disposed of in mined-out pits, one is more confident that the natural rock barrier will change only on a geological time scale. In the case of aboveground tailings facilities, the containment of contaminants will, however, depend on the structural integrity of containment dams, rock or earth covers and diversion dikes. The placement of acid-generating waste rock in lakes relies on the enduring existence of a water cover of sufficient depth to prevent oxidation. Both approaches are susceptible to possible future failures. The engineered structures will degrade slowly through time and changes in weather patterns, as yet unknown, might result in the lowering of the water level of a lake at some distant date.

Secondly, the movement of contaminants might be exceedingly slow even if there is a failure of containment. The movement of contaminants in the groundwater could be of the order of a few centimetres to a few metres per century, depending on the porosity of the rock or glacial till. Consequently, it might take many centuries for contaminants to reach problematic levels in surrounding areas.

Because of these factors, it would be wise to monitor such sites for at least a few centuries in order to confirm model predictions; therefore, in describing monitoring as being required in perpetuity, the panel intends that the regime continue for an unlimited time.

The precise monitoring regime will be site-specific. The groundwater and/or surface water quality will require monitoring, as will the integrity of any engineered structures. Because most of the changes possible would take place very gradually, the monitoring might be infrequent and at increasingly large intervals, in the order of every 10 to 50 years. Consequently, the interest from a small financial endowment would be sufficient to fund the monitoring program in perpetuity.

As important as the funding of perpetual monitoring is the need to have sufficient funds for the mitigation at source of any problems attributed to a failure of containment. We have recommended the establishment of a Uranium Mining Contingency Fund for this purpose (see Section 2.3.2).

Finally, we recommend that northern residents be involved in all aspects of monitoring. The mining companies which perform most of the on-site monitoring are hiring northerners as technicians. Presumably, as training, education and experience increase, northerners will assume supervisory and management roles in the monitoring programs. The regulatory agencies have attempted to involve northern residents in the collection of some monitoring data, and to involve the Environmental Quality Committees (EQCs) in an advisory role.

We acknowledge and applaud these efforts to involve northerners; however, as indicated in the Cigar Lake report, many northern residents are not satisfied and wish to become full partners in the regulatory process. We recommend that the regulatory agencies adopt hiring objectives for northerners similar to those of the mining industry that they regulate. This should be a long-term initiative; in the short term, much of the involvement of northerners will be though the activities of the EQCs.

We are encouraged by the activities of the EQCs and commend the mining companies and government departments for their commitment to work with, and support, these committees. We are, however, acutely aware of the magnitude of the task facing the EQCs. It is vital that adequate continuing financial support be provided to allow these committees to effectively address the many issues related to uranium mining in northern Saskatchewan.

Throughout history, mines of all descriptions have had a reputation for being relatively unsafe places to work. Literature is replete with tales of tragedy experienced by miners and their families. Even in modern times there have been accidents, such as coal mine explosions, that have resulted in the loss of many lives.

Although uranium mines are free of conditions that could lead to the explosions experienced in coal mines, there is still a need to protect workers from a variety of dangers such as the fall of loose rock dislodged from the roof of excavations. In addition to conventional mine safety concerns, uranium miners must also be protected from radiation. Since it cannot be detected by any of the human senses and because its impact does not become apparent until many years after exposure, radiation may be an insidious threat to the health of uranium miners.

During the past six years, we have made site visits to most of the underground uranium mines in Saskatchewan and to all of the open pit operations. In this chapter, we wish to review measures that are being taken at these sites to protect workers, and to make some general recommendations based on our observations.

3.1 Radiation Protection

We are pleased to report that in none of the proposals reviewed has the necessity of providing radiation protection for workers been compromised by goals of higher profitability or greater ease of mining. In fact, many of the mining companies have been innovative in designing mining procedures to ensure maximum worker radiation protection. For example, at the Cigar Lake, Midwest and McArthur River mines, which contain unusually high-grade ore, the proponents have proposed creative ways to remove ore by remote control. Use of automated mining procedures, which have been described elsewhere, [The Cigar Lake Project Environmental Impact Statement, Main Document, Cigar Lake Mining Corporation, July, 1995, pp. 3-30 to 3-77. The McArthur River Project Environmental Impact Statement, Main Volume, Cameco Corporation, October, 1995, pp. 2.3.1 to 2.3.24. The Midwest Project Environmental Impact Statement, Main Document, Cogema Resources Inc., August, 1995, pp. 2-17 to 2-47.] permit mine development to proceed without the need for miners to enter the cavity from which ore is being extracted. In addition, the mine operations are designed in such a way that the ore is contained in well-shielded conduits throughout the entire mining process, thereby greatly reducing worker exposure.

In the past two decades, improved technology has permitted accurate and continuous (as opposed to periodic) monitoring of worker radiation exposure. Research by some proponents has resulted in the development of effective tools for area radiation-source monitoring and personal dosimetry. In addition to the use of a variety of radiation monitoring instruments, mining companies have implemented extensive radiation safety training programs.

Another beneficial innovation has been the development of ventilation models which incorporate radiation source terms. This has enabled mine designers to evaluate the consequences of various mining strategies by modelling, rather than by the trial and error approach which could endanger the health of workers. Based on the models, proponents are able to select the mining techniques which offer the greatest protection to worker health.

When interviewed, workers expressed satisfaction concerning their training and the maintenance of radiation safety standards in mine workplaces. In addition, worker radiation exposure records indicate satisfactory compliance with the regulatory standards established at Saskatchewan uranium mines:

It is therefore of interest to note the excellent radiological control achieved by Cigar Lake Mining Corporation during the Cigar Lake test mine phase. The operation of any underground uranium mine with average worker radiation exposures at five per cent of the annual Saskatchewan dose limit would be a significant achievement. Accomplishing this while mining 20 per cent uranium ore demonstrates the level of radiological safety that is possible with the new mining technologies proposed. [J. Parr, Saskatchewan Labour, Transcript of the McArthur River and Cigar Lake Public Hearings , Regina, Saskatchewan, September 4, 1996, p. 86.]

Despite these achievements, regulatory reform does not appear to have kept pace with the improved understanding of radiation protection that has resulted from research and the use of new technology. The public expressed dissatisfaction with the lack of uniformity between federal and provincial standards and with the length of time required to adopt new standards. Current federal and provincial radiation protection legislation is based upon the 1977 recommendations of ICRP-26, issued by the International Commission on Radiological Protection. Although provincial surface leases require proponents to adhere to the more stringent recommendations of ICRP-60, neither level of government has formally adopted the recommendations of ICRP-60 or the more recent ICRP-65. The updated standards of the ICRP should be adopted by regulatory agencies of both levels of government without further delay.

3.2 Conventional Safety Concerns

Although the long-term safety records at Saskatchewan uranium mines are better than those at operations of other types of mines, three deaths did occur at uranium mine sites in 1995. Presenters noted that the increase in accidents might be attributed to the recent expansion in the number of mining operations which are underground, as compared to the open pit operations which were previously the norm. In light of this, it is puzzling to note that Saskatchewan, a Canadian leader in the development of workplace health and safety legislation, has not completed a review of its Mines Regulations since 1978.

The uranium mining industry in Saskatchewan has undergone a greater evolution than most industries. Its rapid adoption of highly automated, innovative and state-of-the-art mining technologies requires a corresponding adjustment in health and safety regulations in order to maintain worker safety.

Even with appropriate legislation in place, mine workers depend on the efficient and knowledgeable enforcement of regulations to ensure safe work environments. The unique nature of mine workplaces, where workers may be exposed to hazardous conditions in severely confined spaces with limited lighting, necessitates the stringent application and monitoring of standards appropriate to the situation. The panel notes that the mining industry is subjected to intense scrutiny by regulators:

...no other industry in Saskatchewan receives as much attention as the mining industry, when it comes to health and safety. Occupational health committees at mine sites are among the most active in the province. The ratio of mines inspectors to mine workplaces is considerably higher than the corresponding ratio of occupational health officers to non-mine workplaces. [J. Parr, Saskatchewan Labour, Transcript of the McArthur River and Cigar Lake Public Hearings, Regina, Saskatchewan, September 4, 1996, p. 79.]

In view of such intense inspection by the Province, it would be appropriate to expect that a review of mining regulations should be subject to a corresponding level of scrutiny. The current provincial initiative, however, aims to effect mine regulatory change only following a general industry regulatory review. The stated objective infers the existence of a two-tiered system of worker occupational health and safety control. Whereas regular changes have been made to The Occupational Health and Safety Act in Saskatchewan during the past decade, the Mines Regulations have not been changed in two decades. There should be no further delay in reviewing and updating Saskatchewan's Mines Regulations to reflect current mining procedures and the safe use of modern technologies.

3.3 Safety Concerns Related to Transportation

During each of the reviews, members of the public commented on the potential for road accidents and the fear of impacts from spills of hazardous materials into water bodies or the surrounding countryside. In addition, the public indicated concern about the existing condition of the roads, and the implications of additional traffic.

While assessing each individual proposal, the panel accepted that the transportation-related impacts from a specific mining project were not significant, or were mitigable. However, the cumulative impacts of the several mines which are, or will be, operating in a relatively small geographic region of northern Saskatchewan, are of more concern. Where one mine might create 15 trips of ore, chemicals and other bulk supplies per day, and where the impacts caused by that number of trips might be acceptable, the additive effect of several mines operating concurrently is of greater concern.

Some of the safety hazards expected from the heavy vehicles associated with mining traffic include impaired visibility for other traffic on the road due to the dust generated; rapid deterioration of the road surface; and increased risk due to the nature of the loads being carried. The corresponding precautions necessary on the part of the proponents and government are the implementation of dust control measures; frequent monitoring and repair of the road surface; and comprehensive contingency plans for all potential hazards.

It is the responsibility of the provincial government to ensure that the roads available to these projects are adequate to service their combined needs without adverse impacts on other commercial and personal requirements of the area. A comprehensive study of the combined demands made on the northern road system should be completed and additional mining projects should not be approved without a corresponding commitment to provide adequate roads. In general, it would be advisable to bring all northern roads up to southern grid road standards. An improved transportation infrastructure would then become one of the lasting benefits of uranium mining developments in the Athabasca Basin.

Health is widely accepted as being more than the absence of disease; it is a state of physical, mental and emotional well-being. The terms of reference of the panel reflect this broad understanding by encompassing socio-economic effects along with environmental and health considerations. All three potential impacts on health (i.e. direct physical effects, socio-economic effects, and psychological effects) have, therefore, been included in our analysis of the possible effect of the proposed uranium mines on worker and community health.

4.1 Worker Health

In the six-year period encompassing the uranium mining reviews, steps have been undertaken to update and improve health and safety protection for miners. These initiatives include amendments to Saskatchewan's Occupational Health and Safety Act, a review of its Occupational Health and Safety Regulations and a proposed review of its Mines Regulations; amendments to the Canada Labour Code (1996), and the establishment of the 1994 Efficiency of the Federation Initiative. In response to panel recommendations, the province has amended the Occupational Health and Safety Appendix of the uranium mine surface leases to incorporate the intent of ICRP 60 and 65.

Based on presentations made to the panel, it appears that worker radiation exposures at operating uranium mines in Saskatchewan have been maintained below existing dose limits. Mine operators, working with regulators, anticipate being able to meet the new exposure limits with equal success. The panel commends the recent provincial initiative to adopt new international standards for radiation health safety at the uranium mines; however, there is still concern with the length of time taken by both federal and provincial governments to amend safety standards for mine workers. Will the process to amend regulations continue when the public reviews have been completed? We are also concerned with the provincial practice of the amending of radiation protection standards through surface lease agreements, which do not have the permanence of regulations. Will such standards also apply to workplaces other than uranium mine sites where workers might be exposed to radiation?

Similarly, the records on conventional safety issues are generally positive, indicating that mine operators and regulators have been successful in providing adequate worker protection in Saskatchewan uranium mines. There has not been a resolution, however, of the jurisdictional responsibility for conventional occupational safety and health. The provincial government is the jurisdiction actively monitoring worker safety in Saskatchewan, but the federal authority retains the right to initiate prosecution to enforce compliance.

The panel urges the governments to move quickly to amend their appropriate legislation to reflect the new international standards on radiation protection, to expedite the updating of the Mines Regulations, and to resolve the jurisdictional conflict over administrative responsibility for conventional occupational health and safety in uranium mines.

4.2 Epidemiological Studies

The health and safety impacts of a particular industry can be assessed by a statistical comparison of the health-related events experienced by its workers in comparison with those experienced by the general population. In the past, such epidemiological studies have often been used to assess occupational risks and to identify ways in which workplace safety could be improved.

Workers in Saskatchewan uranium mines are exposed to radon progeny, as well as to a number of heavy metals, such as arsenic and nickel, that are known carcinogens. The possibility exists, therefore, that there may be a synergistic effect on the rates of lung cancers caused by multiple exposures. It was for this reason that we recommended in a 1993 report that "arrangements be made to conduct an ongoing epidemiological study of all Saskatchewan miners (past, present and future)." [D.G. Lee, J.F. Archibald, J. Dantouze, R. Neal and A. Yassi, Dominique-Janine Extension, McClean Lake Project, and Midwest Joint Venture, Supply and Services Canada, October, 1993, p.19.]

In response to that recommendation, the AECB, in collaboration with the mining companies and the Province, has formed a multidisciplinary team to prepare a study proposal and to carry out the study. [D. Baris, A Cohort Mortality Study of Saskatchewan Uranium Miners, Atomic Energy Control Board, Submission to Midwest Public Hearings, Saskatoon, May 28, 1996.] This team, which includes epidemiologists, statisticians, industrial hygienists and clinicians from the participating organizations, proposes to study approximately 5,000 Saskatchewan uranium miners employed between 1975 and 2010 at Cluff Lake, Key Lake, Rabbit Lake, McArthur River, McClean Lake and any additional mines that are subsequently approved.

The project will be carried out in two phases. In the first phase, the project team will compare the mortality rates of Saskatchewan miners with those of a standard population in Saskatchewan. In the second phase, after the data collected in the first phase have been subjected to an appropriate statistical analysis, the team will undertake a case-cohort study to further investigate the incidence of lung cancer and any other causes of death for which excess risk is suggested.

This epidemiological study will provide a factual basis on which to assess health implications for uranium mine workers. It will also indicate if the current protection strategies are adequate and, if not, what areas require improvement. Without this information, sound decisions could not be made with respect to possible increased levels of protection.

The study, initiated as a result of the review process, is of potential importance to the protection of mine workers. We, therefore, commend those who have initiated this epidemiological study and recommend that continued financial support be provided to ensure its completion. 

4.3 Community Vitality and Health

Community vitality is defined as the social well-being and quality of life experienced by community residents. The vitality of a community is also intimately connected to community health because it is recognised that the state of our health is affected by factors like employment, income, education, housing, the environment, and individual lifestyle choices.

The uranium mining industry will continue to have a large influence on community vitality and health in northern Saskatchewan because it is a major employer, and has helped to develop road and air transportation routes, and the electrical power grid for the north. Unfortunately, the industry's activities also have the potential to contaminate large areas and poison the air, the water, and the country foods upon which many northerners depend. In addition, there is a communal sense of injustice and anger caused by the extraction of resources worth billions of dollars from their traditional lands while many northerners are struggling to meet basic needs. This collective sense of injustice is one of the main driving forces behind the desire of northern communities for some form of revenue sharing.

It is clear that uranium mining may cause both positive and negative impacts to northern communities. There is a need to identify a set of indicators that can be used to assess more accurately the impacts of uranium mining on the quality of life of northern residents. We commend the leadership of Cameco for offering to provide $250,000 annually towards the funding of a social scientist in the north, and the establishment of a northern community socio-economic and health impacts database. We also welcome the province's commitment to "facilitate discussions among the uranium industry, the Environmental Quality Committees, and the emerging northern health boards to clearly identify the key database indices and additional areas of monitoring." [The Government's Position on Proposed Uranium Mining Developments in Northern Saskatchewan, McArthur River Project, Government of Saskatchewan, May, 1997, p. 22.]

The panel notes that the industry as a whole is taking steps to actively seek the opinion of northern residents on community vitality issues. The industry communicates directly with representatives of the six Athabasca communities via the Athabasca Working Group, and is attempting in that forum to reach a consensus between the peoples of the region and the mining companies on the way in which mining is carried out in the north. The mining companies also committed to continuing their support, in principle and in kind, to the three Environmental Quality Committees, by providing transportation, accommodation, and information for mine site visits, and by listening to the concerns of the committees. [For example, J. Tosney, President, Cigar Lake Mining Corporation, Transcript of Supplementary Public Hearings for Midwest and Cigar Lake, La Ronge, Saskatchewan, August 27, 1997, p. 142.]

There are many signs that the industry is responding to the concerns of northerners. The proportion of northern residents in the workforce is steadily increasing; the way in which contracts are now tendered has resulted in a dramatic increase in opportunities for northern businesses; incentives are provided to encourage northern students to improve their qualifications by staying in school; financial and operational support have been provided for pre-employment training programs as part of the Multi-Party Training Plan; and, employees are provided with education and training opportunities. This list is far from exhaustive but serves to demonstrate that the uranium mining companies are trying to be responsible corporate citizens in the north.

We are also encouraged by recent federal and provincial government initiatives to monitor different aspects of community health, including cumulative effects and the possible contamination of country foods, a baseline community health status survey, and the health study of uranium mine workers. These initiatives should augment the general health planning process for northern Saskatchewan. Both levels of government help fund the Multi-Party Training Plan, and have recently begun discussions with northern leaders on the issues of offloading, taxation, self-government financing and revenue sharing. This latter initiative will likely be a lengthy process, but has the potential to dramatically affect the way many northern residents view uranium mining, particularly if the discussions produce a wider sharing of the benefits.

It is necessary to conclude this discussion of community vitality on a more sober note. Northern residents have exceedingly high expectations of the uranium mining industry. Many hope that it will be the economic saviour of their region; however, the population growth rate in the north is extremely high, making it difficult to provide adequate levels of employment within the region to the increasing numbers of school graduates. It will not be possible, nor would it be advisable, for the uranium mining industry to solve all of the north's economic difficulties. There is a need to diversify the economic base of the north to make it less dependent on a single industry.

Uranium mining produces a boom-bust economic cycle. In spite of the richness of northern Saskatchewan ore, and the current strong market demand for yellowcake, the ore bodies under development will be mined out in about forty years and may or may not be replaced by other discoveries. The cumulative employment and business opportunities created by the operating mines and mills will not last forever. However, the intangible benefits of training and experience acquired through these opportunities are durable cumulative impacts, providing the foundation for a stable employment base and initial integration into the wage economy.

Employment, business opportunities, education and training are inextricably linked, and strongly interdependent. Employment and business opportunities are only available for those who are qualified through education and experience; people are only motivated to acquire education and training if they have a reasonable assurance that jobs and contracts will then be accessible to them.

5.1 Education and Training

Participation by northerners in the workforce, and in its higher paying categories in particular, is dependent on the education and training level of the persons actively seeking employment. Having more jobs available as a result of uranium mining developments may provide motivation for residents to acquire the requisite education and training to enter the mining workforce.

Residents of the north have trailed residents of the rest of Saskatchewan in their qualifications for employment. The 1986 census recorded education data for only two communities in the Athabasca basin, Wollaston Lake and Fond du Lac. Of the potential labour force of 530 persons resident in those two communities, three-quarters were functionally illiterate; i.e., had less than a grade 9 education. Only 5 persons (less than 1 per cent) had obtained a grade 12 certificate. When data for the total province was compiled, only nineteen per cent were functionally illiterate, and 48 per cent had grade 12 or better. [Interim Report, Saskatchewan Environment and Resource Management, May, 1993, Section 2, p. 56.]

More recent figures show an encouraging improvement, produced by many factors. One contributing reason for the improvement is the presence of new schools, or expanded curricula in older schools, which extend the available grades past the Grade 9 level, permitting students to further their education while staying in their home communities. The introduction of adult upgrading courses, the Multi-Party Training Program, NORTEP's Athabasca Bridging Program, and other initiatives have contributed to the gradual improvement of the educational levels of the labour force, and their readiness for meaningful employment. The continuation and enhancement of these initiatives must be diligently pursued. Failure to do so could deny the people of northern Saskatchewan of an opportunity to fully participate in the future of Canada.

5.2 Employment

In the ten years prior to the panel's appointment in 1991, the uranium mining companies' payrolls included between 584 and 1,049 persons annually; of these, the number of northerners employed was consistent, ranging from a low of 201 workers to a high of 336 persons. Expressed as percentages of the workforce, the northern participation rate was 31.2 to 39.9 per cent during the ten-year span between 1981 and 1991. In addition, between 150 and 330 persons were employed on contract at the mine sites. [Interim Report, Saskatchewan Environment and Resource Management, May, 1993, Table 1.4.7.]

Over the next 20 years, the number of workers on company payrolls will fluctuate as some deposits are mined out and the production cycle begins at others. The complementary nature of several projects means that the workforce at the Key Lake and McClean Lake mills will remain relatively stable. Employment should reach a high of over 1,600 employees on various company payrolls by 2003, but drop with the depletion of the Key Lake and Rabbit Lake reserves. The number of contract employees will peak during the construction phases (1997-1999) and level off during production.

As far as cumulative impacts on the north are concerned, the participation rate by northern residents in the workforce is just as significant as the total number of jobs available. In recent years, the rate has shown a gradual steady increase from 31.2 per cent in 1985 to over 50 per cent in 1997. If the proponents meet the terms recommended for the human resource agreements in the McArthur River, Midwest and Cigar Lake surface lease agreements, the northern participation rate will increase by an annual increment of approximately 1 per cent until it reaches at least 67 per cent.

The quality of employment accessible to northern residents has also shown some improvement. In 1992,

...northerners were employed mainly as labour, mill workers, or heavy equipment operators. They comprised a considerably lower proportion of total employees in the higher paying categories of employment - the trades, the technical jobs and the supervisory jobs. [E. Weick, ESAS, A Socio-Economic Overview of Uranium Mining In Northern Saskatchewan, October, 1992, pp. 50-51.]

By October 1996, the situation had started to show signs of change:

...40% of all technical positions, 29 per cent of all trades positions, and 80 per cent of all mill and equipment operator positions are now filled by northerners...much of the progress can be credited to the Multi-Party Training Plan established in December, 1993. [Northerners reap benefits of Multi-Party Training Plan, News Release, Ministry of Northern Affairs, October 7, 1996, p. 1.]

Also encouraging is an increased acknowledgement of the need to accommodate cultural sensitivities, best evidenced by the hiring of an aboriginal employment counsellor by the proponents.

Many of these improvements have been achieved because the proponents were required to accept employment targets as part of the surface lease agreements. Several presenters testified to the positive effect of these targets on hiring practices. Governments should, therefore, continue to present the proponents with achievable but challenging northern employment targets.

5.3 Business Opportunities

The first business opportunities for northerners typically came in areas requiring little capital investment and minimal technical expertise -- security services, catering, and light construction work. Later opportunities included heavier construction projects and transportation-related activities including the transport of employees on their seven-day-in, seven-day-out rotations, the distribution of fuel and supplies, the movement of ore from mine to mill and the delivery of yellowcake to customers.

The final evolution of northern involvement in the mining industry will come when northern residents have the education and experience to fulfil the engineering and scientific research contracts. By the most optimistic estimate, this ultimate involvement is in the distant future.

In 1989, much of the money spent on goods and services was spent in La Ronge, which is a major transportation hub for northern Saskatchewan, as well as being a source for fuel, hardware, lumber and explosives suppliers. Thus, the business opportunities for northern Saskatchewan were limited to a very small area in the geographical south of the region, and were not evenly distributed.

More recently, the encouragement given by the industry to the concept of joint venturing has resulted in the awarding of some goods and services contracts to other areas of northern Saskatchewan; examples are catering (joint venture with Beauval and Domco at McClean Lake, [The Midwest Project Environmental Impact Statement, Supplementary Information, Cogema Resources Inc., May, 1996, p. 2-14.] ) and construction (joint venture with Snake Lake Construction of Pinehouse and Tron Power of Saskatoon [R. Rediron, Transcript of McArthur River Public Hearings, Saskatoon, Saskatchewan, September 11, 1996, p. 185.] ). The experience gained through the joint ventures has enabled some northern companies to access contracts independently. In the future, this should become the norm for many contracts.

In comparison to 1989 figures, business opportunities for the north have shown substantial gains. In 1989, the uranium mines reported spending approximately $23-million in northern Saskatchewan. This was approximately 16 per cent of the operating expenditures of the mines. Transportation services accounted for much of the expenditures. [A Socio-Economic Overview of Uranium Mining in Northern Saskatchewan, E. Weick, ESAS, October, 1992, p. iv.] The more recently proposed uranium mines will be expected to purchase a minimum of 35 per cent of goods and services from northern suppliers. Although it would be tempting to view the gain in northern contracts as a cumulative impact of uranium mining, the increase in business opportunities does not necessarily represent a lasting impact on the north. Some of the businesses will only last as long as the mines are operating, and may not be viable without the major uranium industry contracts. What will endure are the skills and experience gained from the contracts.

5.4 Local Participation

Many people currently living in northern Saskatchewan are the descendants of aboriginal people who have inhabited that part of Canada for many centuries. Because of their long and continuous residency, they have come to look upon northern Saskatchewan as their homeland -- a place to which they are attached both historically and spiritually. It is little wonder, therefore, that they may be dismayed when changes propelled by outside forces take place, and especially if they have little understanding of the possible impacts of those changes on them and on future generations. They have a right to be informed about the developments and to participate in the planning process.

Local people and outside developers must seek effective methods of communication; both have much to gain from a dialogue with each other. It is, therefore, important that local people be provided with an opportunity to express both their aspirations and their concerns about the projects under consideration. Just as importantly, mine operators and government regulators have a responsibility to seriously consider the wishes of local people when the projects are developed. It is essential that the proponents of development projects in northern Saskatchewan find ways to encourage local participation and to make use of any available local knowledge in the planning and implementation of their projects.

The Environmental Quality Committees and the Athabasca Working Group are the best avenues currently available for an exchange of information and ideas. It is therefore in the best interest of all concerned that these organizations be supported and that their participation become an integral part of the planning and regulation processes.

5.5 Environmental Quality Committees

In response to a recommendation contained in our 1993 report, the Government of Saskatchewan established three Environmental Quality Committees (EQCs) in 1995. At approximately the same time, the Northern Mines Monitoring Secretariat (NMMS) was established with an office in La Ronge. [The Government's Position on Proposed Uranium Mining Developments in Northern Saskatchewan, Government of Saskatchewan, December, 1993.] Part of the mandate of the NMMS is to provide support for the EQCs, including the development of educational materials for use by northern residents on how and why monitoring is undertaken and how the information is used.

The members of the three EQCs are representatives from the communities in three geographic regions of northern Saskatchewan. The West Side EQC is comprised of members representing the impact communities identified in the Cluff Lake Human Resource Development Agreement (Beauval, Birch Narrows First Nation, Buffalo Narrows, Buffalo River First Nation, Canoe Lake First Nation, Clearwater Dene Nation, Cole Bay, English River First Nation, Green Lake, Ile-à-la-Crosse, Jans Bay, La Loche, Michel Village, Patuanak and St. George's Hill). The South Central EQC members represent communities identified in the Key Lake and McArthur River Human Resource Development Agreements (Air Ronge, Beauval, Brabant Lake, Buffalo Narrows, English River First Nation, Cumberland House, Cumberland House First Nation, Denare Beach, Green Lake, Ile-à-la-Crosse, La Loche, La Ronge, Lac La Ronge Indian Band, Montreal Lake First Nation, Patuanak, Pelican Narrows, Peter Ballantyne Cree Nation, Pinehouse, Sandy Bay, Southend, Stanley Mission and Weyakwin). The Athabasca EQC consists of representatives of the impact communities for Rabbit Lake, McClean Lake, Cigar Lake and the Midwest Project (Black Lake Denesuline Nation, Camsell Portage, Fond du Lac Denesuline Nation, Stony Rapids, Uranium City and Hatchet Lake First Nation).

A recent publication describes the role of the EQCs:

The EQCs provide a forum where information from government and the mining companies is relayed to the communities, and where communities are able to bring forward their comments on uranium mining projects. It is a mechanism which ensures consideration of the concerns and recommendations of northerners regarding how the uranium resource is developed in northern Saskatchewan. Suggestions and recommendations are forwarded to the mining companies and to governments. In this way the EQCs influence the way in which development occurs. Regulatory authority over the industry, its development and operations remains the responsibility of government. [Environmental Quality Committees and Northern Mines Monitoring Secretariat Report to Communities 1996/97, Saskatchewan Northern Affairs, August, 1997, p. 3.]

The two primary activities of the EQCs to date appear to have focused on the need for the membership to become fully acquainted with the uranium industry in northern Saskatchewan and on their wish to share information concerning the industry with other members of their individual communities.

According to their recent publication, [Ibid, p. 4.] the committees have been very active since their inception. With the assistance of the NMMS Director, Pam Schwann, they have been involved in a large number of activities including:

• a review of the licence renewal documents for Cluff Lake;
• a review of the Environmental Impact Statements for the Midwest, McArthur River and Cigar Lake projects;
• a review of the Conceptual Decommissioning Plans for the Midwest, Rabbit Lake, Key Lake and Cluff Lake mines;
• a review of the Federal Fish Habitat Compensation Policy;
• a review of generic surface lease agreements and human resource development agreements;
• a review of the Cumulative Effects Monitoring Program;
• tours of six mine sites;
• the presentation of briefs at public hearings on the Midwest, McArthur River and Cigar Lake Projects;
• the presentation of briefs to the AECB;
• the development of a proposed Fish Habitat Compensation Plan for the McClean Lake Project;
• the participation in the Caribou Sampling Project in the Wollaston Lake area;
• the development of a recommendation for a review of the abandoned Nisto Mine near Black Lake and implementation of decommissioning activities;
• the attendance at a conference sponsored by the Canadian Aboriginal Minerals Association; and
• a tour of the Saskatchewan Research Council Laboratory in Saskatoon where analyses on air, water, fish and wildlife samples are performed.

In addition to informal exchanges of information between the members and their communities, the EQCs attempt to share information with northern residents by providing meeting minutes and summaries of their activities for each Band and Municipal Council in their area. The NMMS assists them in their efforts to be two-way communicators by preparing educational supplements that are contained in the publication Opportunity North, which is distributed on a semi-monthly basis to every household in northern Saskatchewan. For example, a recent issue contained an excellent summary of tailings disposal technologies. [Opportunity North, Volume 4, Number 3, 1997.]

It is our observation that the EQCs fill a highly important role with respect to the uranium industry in northern Saskatchewan. Through them, northern people are acquiring a better understanding of the industry and its potential for both positive and negative impacts on the people and environments of northern Saskatchewan.

We regard the establishment of the EQCs as being one of the most lasting contributions arising from our work. Providing northern people with a better understanding of this industry and empowering them to participate in its future developments, we are convinced, is the best way to protect the northern environment.

We commend the Province for its foresight in establishing these committees and we strongly recommend to both the federal and provincial governments, as well as to the mining companies, that they continue to support the work of these committees. Governments should ensure that they are provided with sufficient funding to fulfil their mandate and the companies should continually seek ways to provide them with any required information in a manner that is both accurate and understandable.

5.6 Revenue Sharing

The panel first became aware of the wish by northerners to share in the revenues generated by uranium mining during scoping sessions held in 1992. [L. Wolfe, Summary Report on Scoping Meetings for Cigar Lake and McArthur River Projects, 1992, pp. 44-45.] The desire on the part of northern residents for a program of revenue sharing became a recurring theme whenever we were in northern communities and we subsequently made recommendations in support of revenue sharing in each of our reports.

In retrospect, it would appear that a great deal of the concern with respect to revenue sharing may have been a result of unfulfilled expectations that had been created by the Cluff Lake Report in 1978. [E.D. Bayda, K. McCallum and A. Groome, Final Report Cluff Lake Board of Inquiry, May, 1978, pp. 187-194.] The provisions of that report, which called for the provincial government to, "institute a uranium royalty sharing scheme under which the government would pay a share of the uranium royalty to certain northern governing bodies", were never implemented, much to the disappointment of many northerners.

In our 1993 report we recommended that, "no new uranium mining developments be undertaken until a form of revenue sharing, acceptable to the majority of impacted communities, has been agreed upon". [D.G. Lee, J.F. Archibald, J. Dantouze, R. Neal and A. Yassi, Dominique-Janine Extension, McClean Lake Project, and Midwest Joint Venture, Supply and Services Canada, October, 1993.] In response, the provincial government implemented a rather large number of initiatives including a commitment to share in the cost of the Multi-Party Training Plan, the introduction of amendments to the Northern Revenue Sharing Trust Account that would allow for greater northern participation in setting priorities for use of that fund, the establishment of a Northern Development Fund to assist northern business activities, the introduction of a Northern Mines Monitoring Secretariat to provide the public with accurate and credible information concerning the mines, the initiation of an integrated cumulative effects monitoring program, improvements to the road between La Ronge and Points North Landing, and the establishment of Environmental Quality Committees for each group of impact communities to improve the communication of information concerning the mines. [The Government's Position on Proposed Uranium Mining Developments in Northern Saskatchewan, Government of Saskatchewan, December, 1993.] However, when we returned to public hearings on the Midwest Project in the spring of 1996, it was clear that these measures had not been recognized by most northerners as a form of revenue sharing, perhaps because they had not been directly involved in the development of these programs. Resentment with respect to the perceived failure of governments to respond in a satisfactory manner continued to grow and was, we believe, the primary reason why some of the northern communities boycotted our 1996 hearings on the McArthur River and Cigar Lake projects.

Following the release of the McArthur River report, [D.G. Lee, J.F. Archibald and R. Neal, McArthur River Uranium Mine Project, Supply and Services Canada, February, 1997.] the Premier of Saskatchewan and six of his Cabinet responded to one of the recommendations in that report by meeting with northern leaders in Saskatoon on May 12, 1997. Revenue sharing and other matters were discussed and an agreement to hold another meeting was announced. [Government and northern leaders meet to discuss northern issues, News Release, Executive Council, Government of Saskatchewan, May 12, 1997.] Subsequently, the Province announced the initiation of a dialogue with northern leaders to develop a "Northern Strategy that fully reflects the social and economic priorities of northern people". [T. Penikett, Submission of the Government of Saskatchewan to the Federal-Provincial Review Panel on Proposed Cigar Lake and Midwest Uranium Mine Developments, La Ronge, Saskatchewan, August 28, 1997, pp. 2-4.] At the same time, it was revealed that the Provincial Minister of Intergovernmental and Aboriginal Affairs, the Minister of Indian and Northern Affairs Canada, and the Chief of the Federation of Saskatchewan Indian Nations had signed a tripartite Fiscal Table. The purpose of this agreement is "to negotiate fiscal arrangements on several related financial issues including offloading, taxation, self-government financing and revenue sharing". [Ibid, p. 4.]

We understand that solutions to the concerns which northerners have with respect to revenue sharing and related issues will not come easily. It is apparent that the decisions which flow from these initiatives may have broad implications that extend beyond northern Saskatchewan. It is noteworthy that similar discussions are taking place in other provinces [The Globe and Mail, Quebec agrees to negotiate with Crees, June 13, 1997.] and there will be a need for consistency between jurisdictions. At the same time there is a need to act in a timely fashion, before all of the uranium has been mined, milled and marketed.

As a panel, we believe that our responsibility for drawing this issue to the attention of governments has been discharged now that discussions with northern leaders have been initiated. In many respects, the issue is primarily political and only peripherally related to environmental assessment. We are, therefore, satisfied that resolution in a political forum has begun. We can do little more to assist northerners in their efforts to benefit from the removal of riches from an area that they have for generations regarded as their homeland.

The comments previously made in this report have directly addressed issues contained in our terms of reference; i.e., environmental, safety, health and socio-economic concerns. There are, however, a number of important concerns that were raised during the reviews which do not fit neatly into any one of the previous sections. An attempt has been made to summarize some of these issues in this section.

6.1 Industry Regulation

To be effective, regulators require the support of the industry and the public. The industry is looking for elimination of duplication between federal and provincial regulators, and streamlining of the regulatory process. The public is looking for assurance that these projects can be operated safely and without adverse environmental impacts.

The level of public confidence, although satisfactory with regard to the provincial regulation of conventional health and safety, is less strong regarding the federal regulation of nuclear undertakings. This lack of confidence is due, in part, to the apprehension often attached to nuclear issues. Efforts should be made to enhance the confidence of the Saskatchewan public, through education regarding nuclear and mining issues, and through the increased involvement of northerners in monitoring and regulatory activities.

Although members of the public occasionally expressed a lack of confidence in the regulatory process, our conclusion, after careful study of the system, is that the industry has been well regulated in the Province of Saskatchewan. In our estimation, workers and the public have been protected without subjecting the operators to excessive requirements. There does appear, however, to be room for a better definition of responsibilities between the two levels of government and, where overlap of jurisdiction cannot be avoided, for greater cooperation and efficiency.

6.2 Industry Viability

The environmental damage caused by development of mines cannot be justified unless the projects produce compensating benefits. The economic benefits that will flow from mine development will be directly dependent on the price of uranium, which will, in turn, be governed by the laws of supply and demand. Therefore, an environmental review should also assess the likely future demand for uranium.

Assessments concerning the economic benefits of uranium mining made by the Cluff Lake and Key Lake Boards of Inquiry were altogether too optimistic. [E.D. Bayda, A.J. Groome, K.J. McCallum, Final Report, Cluff Lake Board of Inquiry, 1978, p. 165. R.W. Mitchell, D. Smyth, M.M. Tomilin, J.P. Roberts and W.N. Riese, Key Lake Board of Inquiry Report, 1981, pp. 21-22.] The promise of high prices that existed in the late seventies and early eighties encouraged an over-production of uranium which consequently forced prices down. In fact, some of the resultant surplus inventories still exist. However, since current global production is only about one-half of the world-wide demand, the surplus inventories are rapidly being diminished and the demand for uranium is predicted to increase modestly over the next two decades. Therefore, the price is also likely to increase somewhat over the next decade.

Evidence received by the panel from various sources agreed with the prediction that the increased demand for uranium in the next decade would contribute to making the industry profitable and result in substantial benefits for the federal and provincial governments. For example, a joint report by the OECD Nuclear Energy Agency and the International Atomic Energy Agency states that:

World electrical energy use will continue to expand over the next several decades to meet the needs of rising population and sustained economic growth. After the turn of the century, electricity demand in the developing countries will likely grow at two or three times the rate in the developed countries. Most new nuclear capacity is forecast for these regions. Globally, over the thirty year term from 1990 to 2020, nuclear electricity generation (and the corresponding uranium requirements) are expected by many experts to grow by about a factor of two. [URANIUM, 1993 Resources, Production and Demand, Nuclear Energy Agency, Organization for Economic Cooperation and Development, Paris, 1994, p. 14.]

In addition, the Province completed independent assessments of each of the projects which, as discussed in each of the individual reports, predict positive cash flows and a good rate of return on investment. All indications at this time, therefore, are that the industry will be economically viable.

6.3 Nuclear Non-Proliferation

Although the Government of Canada prohibits the use of Canadian uranium in nuclear explosive devices, it permits the sale of uranium to foreign buyers in accordance with its policy of fungibility. This policy requires that, for all Canadian uranium sold, an equivalent quantity must be accounted for in non-military applications. However, no process exists to separate Canadian uranium from uranium acquired from other sources; the policy of fungibility fails to provide assurances to the public that Canadian uranium will not be used in weaponry.

One suggestion made to address this shortcoming was the implementation of a coordinated international application of the fungibility concept with governments of other uranium-producing nations; i.e., a cumulative international fungibility policy.

Also at issue is the continued sale of Canadian uranium to countries which have recently tested nuclear weapons or otherwise violated the intent of internationally ratified agreements, such as the Nuclear Non-Proliferation Treaty to which Canada is a signatory. Further, some members of the public stressed their concern over ongoing uranium mining activities in Canada by companies owned by the governments of these same countries.

A participant suggested that Canada might address these concerns by revoking the licence of companies owned by foreign governments that test nuclear weapons and/or by prohibiting, for a period of five years, sales of uranium to countries that have violated the Nuclear Non-Proliferation Treaty. [P. Prebble, Transcript of Public Hearings, Saskatoon, Saskatchewan, June 14, 1996, p. 145.] Such a measure could prove to be a powerful incentive for governments to comply with international agreements to which Canada is a signatory.

6.4 Genetic Effects of Ionizing Radiation

One concern of the general public is that increases in ionizing radiation, particularly from the alpha radiation emitted from particles ingested by organisms, will lead to genetic problems in the biota. Although not stated explicitly, the fear seems to be that increases in ionizing radiation will cause an increase in the mutation rate and that harmful mutations will build up in the biota until the organisms are no longer viable. This is not a trivial concern; however, based on a knowledge of the genetic effects of radiation and the study of population genetics, scientists have concluded that there is little risk.

First, it is acknowledged that increases in ionizing radiation lead to an increase in the mutation rates of organisms; [This effect was first observed about 70 years ago in experiments by H.J Muller, using X-rays on fruit flies, and by L.J. Stadler, using X-rays on barley. Subsequently, this was shown to be a general response of organisms.] however, large doses of radiation are required to make an appreciable change in mutation rates. For example, with mice, it has been estimated that each additional dose of 10 mSv would induce about 1.5 x 0-7 mutations at each gene locus. [A.P. Mange and E.J. Mange, Genetics: Human Aspects, 2 nd Edition, Sinauer Associates, Sutherland, Massachusetts, 1990, p. 265.] It would take a dose of about 1000 mSv to double the normal mutation rate for this species. For human populations, it has been estimated that a radiation dose of 500 to 2500 mSv would be required to double the natural mutation rate. [Ibid.] Other organisms may be more or less sensitive in their response to ionizing radiation, but all require large doses of radiation to appreciably change their mutation rates.

Secondly, the mutations induced in organisms by ionizing radiation are no different than natural spontaneous mutations. While a few may be beneficial, most will be either neutral (i.e. seemingly no better or worse than the original gene), or harmful. The new mutations, whether they be spontaneous or induced by mutagenic agents such as ionizing radiation, occur at a very low frequency ranging between about 1 in 100,000, to 1 in 100,000,000 per gene, per generation. Thus, even with many thousands of genes in each germ cell, there will be few new mutations in each generation. It has been estimated that each human being carries about two new mutations; [F.J. Ayala and J.W. Valentine, Evolving: The Theory and Process of Organic Evolution, The Benjamin/Cummins Publishing Company, Menlo Park, California, 1979, p.93.] most organisms other than humans will carry far fewer new mutations because they have fewer genes.

Increasing the mutation rate would have surprisingly little effect on the genetic structure of the population. This is because any new variation arising in each generation by mutation is only a minute fraction of the total amount of genetic variation already present in the population. Most organisms carry thousands of mutations as a result of their accumulation in the population over many thousands of generations; humans are no exception. In general, it is estimated that any new variation being added through mutation to the population each generation is less than one-thousandth of the existing variation in that population. [Ibid, p. 94.] In addition, most new mutations will not survive in the population because they will be eliminated either by selection, or by chance. Scientists have concluded, therefore, that mutation pressure has little effect on the genetic structure of populations. What changes do occur, tend to occur slowly.

In conclusion, the hazards posed by the genetic effects resulting from increases in ionizing radiation from uranium mining are likely to be small or insignificant. Natural spontaneous mutation rates occur at very low frequencies and it requires large doses of radiation to change these rates substantially. To increase the mutation rates to levels where they could dramatically change the genetic structure of populations in a harmful way would require doses of ionizing radiation, where we would be more concerned with the direct lethal effects of radiation rather than the genetic effects.

6.5 The Environmental Assessment Review Process

This panel received its mandate jointly from the federal and provincial governments in 1991 and has conducted independent public environmental assessment reviews of seven different uranium mining proposals. In conducting the public reviews, certain precedents occurred which merit comment.

This review was the first environmental assessment review undertaken jointly by the Governments of Canada and Saskatchewan. By using one process to address the legislative and regulatory needs of both governments, it was possible to eliminate duplication and reduce the costs and time required.

The mandate given the panel was the first to include the consideration of the regional cumulative impacts resulting from development of several projects within the same timeframe and geographic area. The panel reviewed the mining of nine ore bodies, the construction of one mill, the design of two tailings management facilities and the expansion of associated transportation infrastructure. Because the review period was lengthy, panel members were able to acquire a comprehensive knowledge of the technical aspects of the proposals, while at the same time assimilating the economic and social climate of the region for which the developments are proposed. This is significant; no development occurs in isolation, either from the physical environment or from socio-economic conditions. By reviewing several projects under a single mandate, it was possible to consider the cumulative environmental and socio-economic impacts of all of the proposed developments.

Another advantage of consolidating seven proposals under one review process was that it allowed for the investigation of options to reduce the overall impact of the developments by combining some aspects of their operations. A good example of this is the decision to custom mill ores from several mines at a few sites, thus reducing the number of mills and tailings management facilities to be built and decommissioned.

The fact that this review panel was convened for more than six years did present some difficulties. The logistical problem of maintaining the involvement of panel members for the duration became apparent when two of the panel members resigned before all of the reviews had been completed. For all members, panel responsibilities were an addition to their primary employment, and the demands on their time were often difficult, or impossible, to reconcile. This would likely be a consideration for any future panel with multiple reviews in its mandate.

Another significant problem relates to the fact that the environmental assessment process, designed as a planning tool, reviews the concept of any proposed developments to enable decisions to be made before irrevocable actions are taken. For a conceptual review, the proponent must choose a point in time at which sufficient information is available to prepare an environmental impact statement and must base its predictions on the amount of information available at that time. This confers a static nature on the environmental assessment process. This is particularly difficult to reconcile when an EIS for one proposal is based on information common to another, previously approved, project that is generating site-specific information for licensing approvals. This was the case in the Midwest and Cigar Lake reviews: The static nature of the environmental assessment of their tailings management facility proposal was in conflict with the dynamic nature of the licensing process ongoing for the same facility, the JEB TMF. In the future, if similar reviews are undertaken, careful consideration must be given to coping with the possible interaction of conceptual information from one proposal and site-specific data from another.

Throughout this review, the panel and secretariat heard a certain amount of criticism regarding the public environmental assessment review process. Some of the concerns related to the duration of the reviews; to the amount of time permitted for the public to assess the complex technical details of the proposals; and to the scope of the panel's mandate. As with any legislated process, environmental assessment tries to respond to the varied interests of all participants, while achieving its objectives. We are comfortable with the balance achieved by the processes of the Governments of Canada and Saskatchewan and suggest, in response to the criticisms heard, that careful consideration be given to what alternatives might be instituted if the process were to be changed.

The projects under review were extremely technical in nature. As a result, both governments provided intervenor funding to assist members of the public in conducting their reviews of the EISs. We appreciate the efforts made, and emphasize the value of the contributions of the public in assisting us to formulate recommendations. The public nature of the environmental assessment process is its most important feature. Above all else, it must be encouraged and protected.

During the six-year lifetime of the review, it was occasionally suggested that the panel might not have been completely free of political interference. [See, for example, M. Penna, Transcript of Supplementary Public Hearings for Midwest and Cigar Lake, La Ronge, Saskatchewan, August 27, 1997, p. 149.] Some participants alleged that officials from the federal and provincial governments might somehow have applied pressure on the panel to make recommendations which they favoured. Nothing could be farther from the truth. Representatives from both levels of government scrupulously avoided interference in the panel's work in any way. In fact, the only people who attempted to corrupt the process by using their influence to effect political interference in the environmental assessment reviews were the Saskatchewan Bishops. [Star Phoenix Uranium hearings not working, bishops say, November 27, 1996, p. 3.]

The public process conducted on these projects took place in a manner that was independent of both government and industry. All review activities were made as transparent as possible and all documentation was open to public scrutiny. An attempt was made to conduct the hearings in a non-judicial manner, allowing full comment by members of the public, industry and government. These were among the most extensive hearings ever undertaken in Canada. As shown by their responses to panel recommendations, both the Governments of Canada and Saskatchewan gave careful consideration to our reports before making decisions regarding the projects under review. We are satisfied with their responses to our work.

7.1 Education

During the past half-decade, the Multi-Party Training Plan and related programs have made it possible for increasing numbers of northern residents to find employment in various industries, particularly mining. These educational initiatives should be encouraged and we recommend that the Multi-Party Training Plan, or an improved program for training-to-employment, be renewed. Continued improvement of the K to 12 and college system is also important to permit the people of northern Saskatchewan to share in the opportunities offered by uranium mining and other industries.

7.2 Employment and Business Opportunities

In the past, Human Resources Agreements attached to the surface leases for mines have provided the mining companies with encouragement to hire residents of Saskatchewan's north and to use northern contractors as providers of goods and services. This approach has worked well, causing northern employment levels to increase steadily and providing northerners with an incentive to establish a variety of businesses. The Province should continue to attach similar requirements to surface lease agreements. The industry-wide objectives should be to increase northern employment participation to at least 67 per cent and to maintain northern business involvement at 35 per cent or greater. The Province should not allow its mineral resources to be depleted without compensating benefits that will assist the people of northern Saskatchewan to fully participate in the future of Canada.

7.3 Community Vitality

The vitality of northern communities must be protected during adjacent development of the uranium mining industry. To avoid the possibility of continuing detrimental effects on northern communities, qualified professionals should be engaged to identify a set of indicators appropriate for monitoring and studying the impacts of uranium mining on the quality of life in northern Saskatchewan. Cameco has generously offered to provide $250,000 annually towards funding such a study and for the establishment of a northern community socio-economic and health impact database. It is recommended that the federal and provincial governments work in conjunction with Cameco to ensure that this program is initiated in a timely fashion and that it receives the necessary support to operate effectively.

7.4 Research

Uranium mining is going to continue in northern Saskatchewan for at least several decades. Applied research directed toward the development of more efficient and environmentally friendly ways to process the ore and store the tailings would likely prove to be a good investment. The panel recommends that such research be carried out by the Province in cooperation with the AECB and the mining industry, using laboratories located at the Saskatchewan Research Council (SRC) or one of the Saskatchewan universities. The Petroleum Division of the SRC could serve as a model for a program of industry-related applied research.

7.5 Mills

The practice of milling ores from several mines at a single mill should be encouraged. Less environmental damage, in total, will result from the combined milling of several ores as compared to mills and tailings management facilities near each mine. Long term monitoring will also be more feasible if there are fewer sites that require attention.

7.6 Tailings Management Facilities

Tailings are the greatest long-term source of potential environmental contaminants associated with these projects. Construction of reliable tailings management facilities is, therefore, of primary importance. We recommend the use of subsurface deposition in mined-out pits. Care should be taken when a site is selected for subaqueous tailings disposal. It is usually better to choose a site after the pit has been completely mined out and the geology and hydrogeology of the surrounding formations have been thoroughly studied.

7.7 Waste Rock

Deposition of potentially acid-generating waste rock on the surface must be avoided. In order to ensure that surface deposition does not happen, we recommend that research be undertaken into better methods for separating inert and potential acid-generating waste rock.

We do not favour the use of lakes as waste depositories if other options are available. Ideally, potential acid-generating waste rock should be returned underground or placed in mined-out pits. When pits are used, they should be completely filled and capped with several metres of inert waste or till to prevent the formation of a pond that might eventually become polluted by upward diffusion of contaminants from the waste below.

7.8 Long-Term Monitoring

The facilities that have been developed to store uranium mill tailings will each contain millions of tonnes of waste that is both toxic and radioactive. Since humankind does not have experience with the maintenance of facilities over the length of time required for the wastes in these storage pits to become benign, it will not be possible to leave the sites completely unattended in the foreseeable future. Although the tailings management facilities may perform as predicted and require little mitigative action, it would be foolhardy to proceed on that assumption. Previous experience with tailings disposal systems teaches that it would be more prudent to monitor continually and be prepared to handle unexpected eventualities. If the facilities prove to be operating well, the frequency of monitoring could decrease, but the need for periodic checks will never completely disappear. For this reason, we recommend the establishment of an authority that could monitor all sites on a continuing basis and provide mitigation as needed.

7.9 Cumulative Effects Monitoring

The potential spread of contaminants is assessed on a regional scale by the Cumulative Effects Monitoring Working Group (CEMWG), which was established in 1994 by Saskatchewan Environment and Resource Management and the Atomic Energy Control Board. The Environmental Quality Committees support this initiative because of the strong ties that northern residents have to the land. It is important that adequate funding continues to be provided for this work, and that local residents become more intimately involved in the activities of the CEMWG.

7.10 Environmental Quality Committees

Formation of the Environmental Quality Committees is one of the most important consequences of these reviews. Providing northern people with a better understanding of the uranium mining industry and empowering them to participate in its future development is the best way to protect the northern environment. We strongly recommend to both the federal and provincial governments, as well as the mining companies, that they continue to support the work of these committees.

7.11 Roads

Almost all northern development places additional requirements on the existing roads. There is a need for a comprehensive study of the cumulative demands that will be placed on the northern roads in the next decade and beyond. The province should complete such a study and be prepared, in cooperation with the users, to provide the roads required and to maintain them at acceptable standards. An improved transportation infrastructure may be one of the primary legacies of uranium mining developments in northern Saskatchewan.

7.12 Worker Health and Safety

Mine workers, particularly those in underground developments, depend on mine regulators to ensure safe workplaces. It is, therefore, essential that legislation and regulations provide adequate protection for both contract and non-contract workers; that mine sites be inspected frequently; and that due care be exercised to ensure that safe work practices are being followed.

During the six-year review period, the panel has witnessed some extraordinary changes. The number of northerners employed has increased, with specific pre-employment training plans having been developed to facilitate the wish of many northern people to find steady employment. There has been a major growth in the number and types of opportunities for northern businesses. We have seen the creation of the Environmental Quality Committees and the Athabasca Working Group to provide northern residents with an opportunity to have a greater influence on the activities of the uranium industry and associated government regulatory departments. The cumulative impacts of uranium mining are being studied by the Cumulative Effects Monitoring Working Group. Financial securities are now required for the decommissioning of all mine facilities before they are constructed. Attempts are being made to develop a socio-economic and health impacts database for northern communities. The issue of resource revenue sharing is being discussed between the federal and provincial governments and northern leaders. These examples of progress are impressive.

It has been exciting to grapple with the question of whether or not uranium mining should expand in northern Saskatchewan and, if so, under what conditions it should be allowed to proceed. We have listened to diverse opinions offered by many members of the public and have considered these opinions when developing recommendations in our reports to guide both the federal and provincial governments. We are satisfied that both levels of government have listened to our advice carefully and have, generally, responded in a positive way.

We are concerned, however, that the momentum for change and new initiatives might be lost with the completion of the panel process and the lessening of opportunities for the public to challenge and question what is going on. We also acknowledge the difficulty we have had in forecasting future events and priorities. What makes sense now may appear to be less reasonable in a few years.

For these reasons, we recommend that a retrospective be held after approximately ten years to consider how effective the panel process has been in the long term. Such a retrospective would help the federal and provincial environmental review agencies, CEAA and SERM, to evaluate the benefits of the environmental assessment process. There are several questions to be answered: Did it make a difference over the long term? How precisely do values predicted during the environmental assessment process match observed values for financial revenues to governments; employment levels for northern residents; business opportunities for northerners; site-specific emissions of contaminants; and the impact of operations on the biota both on-site and in a regional cumulative setting? How many panel recommendations were accepted by the provincial and federal governments, and how faithfully were they implemented? What is the continuing status of the many initiatives introduced as a result of the public reviews (e.g. the Environmental Quality Committees, the Athabasca Working Group, the attempts to measure and monitor northern community health and vitality, and the epidemiological study of the incidence of lung cancer and mortality of uranium mine workers)?

Answering such questions will require the cooperation of the industry and government departments. We suggest that CEAA and SERM would be the appropriate bodies to initiate and facilitate such a retrospective. We would suggest that the review itself be contracted to an independent body which should not include either present or former panel members. We also recommend that the retrospective include involvement of the public in some manner.

In the final analysis, the impacts of the many projects we have reviewed will have a dramatic effect on the people of Saskatchewan, particularly in the north. All participants in the environmental assessment reviews deserve to know if their efforts ensured mitigation of the negative impacts, and accentuation of the positive impacts.