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. Membership of the joint panel is summarized in Section 1.2.1 and its mandate is found in Section 1.2.2 and Appendix B. This is the fifth report submitted by the joint panel.

After consultation with interested stakeholders, the joint panel issued Guidelines for the Preparation of Environmental Impact Statements and Government Information Requests for the Cigar Lake and McArthur River Projects, in September of 1992. Responding to these Guidelines, the Cigar Lake Mining Corporation (CLMC) submitted its Environmental Impact Statement (EIS) on October 4, 1995. Additional information was received on April 1, 1996, July 12, 1996, December 12, 1996 and May 2, 1997.

This report is based on information that was obtained from reading the entire Environmental Impact Statement; from an information meeting with CLMC in La Ronge on January 23 and 24, 1996; from nineteen days of public hearings in Pinehouse, La Ronge, Saskatoon and Regina; and from written reports submitted by individuals, organizations and government departments or agencies. The major recommendations are identified in Chapter 4. The rationale for the recommendations and the attendant conditions may be found in Chapters 5 - 14.

Developments, even if located in the sparsely populated northern regions of our country, do not occur in isolation. People, as well as the environment, are affected by the opening of a new mine such as the one proposed at Cigar Lake. Our philosophy in completing this review has, therefore, been to assess as thoroughly as possible the impacts of the project on northern people, as well as on the northern environ-ment. In our view, impacts on the vitality of northern communities, for example, are as significant as impacts on the biota. Both are important; both must be protected and, if possible, enhanced by the deve-lopment of this project.

Approval of the Cigar Lake Project is recommended with certain reservations. The reservations are asso-ciated primarily with the use of the proposed JEB Tailings Management Facility where the tailings produced from the milling of the Cigar Lake ore would be stored and with the selection of a site for disposal of mine waste rock.

It is recommended that approval for mining, as described in the Environmental Impact Statement, be granted subject to the ability of the proponent to locate an environmentally acceptable place to dispose of mine waste rock. Disposal in an existing lake should be avoided if other acceptable sites, such as a mined-out pit, are available.

CLMC proposes to custom mill its ore at the JEB mill, operated by Cogema Resources Inc., at McClean Lake. We recommend approval of the concept for tailings disposal represented by the JEB Tailings Management Facility (TMF), but with major site-specific reser-vations. The proposed JEB TMF, to be constructed using natural surround technology, is an attractive option for tailings disposal because it provides an opportunity to realize several environmental benefits relative to other methods for tailings disposal. Among these benefits are an increase in worker protection through the use of subaqueous deposition; reduction of environmental disruption at several locations, as a result of combining deposition of tailings from many ore bodies at one site; the avoidance of engineered barriers which may fail in the long term; the minimization of weathering problems; and the protection of the contents of the pit from scarification by glaciers during the next ice age. Because of these potential advantages, the concept for tailings disposal represented by the JEB TMF proposal is recommended. However, there are critical site-specific technical and managerial concerns that must be resolved before this particular tailings management facility can be recommended. Chief among the technical concerns is the need for convincing evidence that operation of the TMF would not result in the contamination of Fox Lake in the long term. This concern is exacerbated by a lack of confidence in the managerial and scientific competence of the operator, Cogema. In addition, the obvious dismissive attitude of this company for the regulators and their concerns suggests that it would not be appropriate for Cogema, as currently managed, to be given responsibility for constructing and managing this very dangerous radioactive waste disposal facility.

We are aware that resolution of these concerns, likely to cause a long delay in the licensing process, would have fiscal implications. The wish to maximize immediate economic benefits from the development of these resources does not, however, justify the approval of this facility until it has been demonstrated that all reasonable environmental safeguards are in place.

It is recommended that long-term monitoring be introduced to protect future generations from unacceptable impacts. This is particularly important if approval is eventually given for the tailings management facility. Arrangements should be made to monitor this site in perpetuity, and resources retained to mitigate any undesirable impacts. It is for this reason that we reiterate our previous recommendation for the establishment of the Uranium Mining Contingency Fund, and an authority to oversee it.

Local participation in the monitoring protocols is essential. The Environmental Quality Committees and the Athabasca Working Group provide good vehicles for local participation. It is recommended that their participation be enhanced by the provision of adequate financial support and, in the case of the Athabasca Working Group, by the adoption of measures that will give it a more formal, permanent status.

A number of initiatives, described in greater detail in the body of the report, have recently been undertaken to monitor different aspects of community and worker health. It is recommended that sufficient funds be made available to ensure that these initiatives are able to continue until the completion of their mandate.

The Cigar Lake Project, if approved, will provide much-needed opportunities for some northern people to find employment and to benefit from business contracts. The EIS indicates that CLMC expects to reach an employment level of 50 per cent northerners within five years of operations start-up. This is an unacceptably low expectation in light of the funds that have been spent and the efforts that have been made to prepare northerners for employment through the Multi-Party Training Plan and other programs. We are recommending a minimum of 50 per cent northerners in the CLMC workforce from the beginning of the project with an increase in northern participation of 1 per cent per year until it reaches at least 67 per cent. We are also recommending that an objective of obtaining at least 35 per cent of all required goods and services from northern suppliers be established for the Cigar Lake Project.

We are pleased to note the progress that has been made on the formation of a Fiscal Table that will permit a tripartite negotiation between Saskatchewan, Canada and FSIN of fiscal matters, including revenue sharing, that are related to northern development. We urge that programs arising from these initiatives be implemented in a timely fashion, before the resource is further depleted.

1.1 Review Process

In April, 1991, the governments of Canada and Saskatchewan announced a joint federal-provincial environmental assessment review to study several uranium mine developments in northern Saskatchewan. The Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan was appointed in August, 1991, to conduct a public review of the proposed developments. Included in the review was a proposal to mine the Cigar Lake ore body, where test mining activities were already underway. [The federal referral was made by the Minister of Energy Mines and Resources, on behalf of the Atomic Energy Control Board, citing Section 11(b) of the Environmental Assessment and Review Process Guidelines Order; the provincial referral was made by Saskatchewan Environment and Public Safety, citing the Environmental Assessment Act and the Public Enquiries Act.] The Cigar Lake Mining Corporation (CLMC), a consortium of four companies, was designated as operator.

After consultation with interested stakeholders, the joint panel issued Guidelines for the Preparation of Environmental Impact Statements and Government Information Requests for the Cigar Lake and McArthur River Projects (Guidelines), in September of 1992. Responding to the Guidelines, CLMC submitted its environmental impact statement (EIS) for full-scale mining at Cigar Lake, on October 4, 1995.

The panel conducted an information meeting with the proponent in January of 1996 to discuss the adequacy of the information submitted in the EIS. This meeting supplemented the comments received from members of the public, from organizations and from provincial and federal government departments and agencies. To facilitate a complete understanding of the proposal, the panel requested additional information from CLMC on February 20 and May 22, 1996. CLMC responded to these requests on April 1, 1996 and July 12, 1996, respectively.

When the panel concluded that sufficient information to adequately review the project was available, public hearings were scheduled in Regina, Saskatoon, and nine northern communities. The panel accepted locations for the community hearings in northern Saskatchewan based on the advice of the Environmental Quality Committees. [Environmental Quality Committees consist of representatives appointed by the communities that are impacted by uranium developments in northern Saskatchewan.] However, scheduling arrangements, which had been confirmed in advance with the communities, had to be changed to accommodate several chiefs and mayors who withdrew their invitations a few days before the sessions were to take place. The panel rescheduled all sessions, and held hearings in Regina, Saskatoon, La Ronge, and Pinehouse in September and October, 1996.

Shortly before the hearings were due to begin, the proponent announced its intention to revise its plans for the JEB Tailings Management Facility and, on August 26, the panel requested CLMC to prepare comprehensive information on its revised proposal. The panel's intent was to deal with the tailings disposal issue at separate sessions of public hearings, after the new information had undergone the customary review phases.

Information on the revised tailings disposal plan was submitted by the proponent on October 31, 1996, with additional information being requested by the panel on December 12. On May 2, 1997, the panel received sufficient information to permit a comprehensive review of the proposed revisions and the supplementary public hearings were held at La Ronge, Saskatchewan, in August, 1997. After the completion of all sessions of public hearings, the panel prepared the following report.

The governments of Saskatchewan and Canada made $75,000 available for participant funding to help the public take part effectively in the review. The funds were intended to assist recipients in reviewing the EIS and in preparing for and participating in the public hearings. The allocation of funding was done by an independent committee, with no involvement by the panel. A summary of the participant funding allocations is found in Appendix F.

1.2 Panel

1.2.1 Membership

The Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan was appointed on August 22, 1991. Donald Lee, Professor of Chemistry at the University of Regina, is Chairperson of the panel. Other panel members are:

• James Archibald, Professor and Acting Head of Mining Engineering at Queen's University; and
• Richard Neal, Professor of Biology and Associate Dean (Academic) of the College of Arts and Science, University of Saskatchewan.

Annalee Yassi, Associate Professor and Director of the Occupational and Environmental Health Unit, University of Manitoba, participated in the Cigar Lake review until her resignation in August, 1996. John Dantouze, Vice-Chief of the Prince Albert Grand Council, served as a panel member until October 1, 1996, when he resigned.

1.2.2 Mandate

The mandate of the panel is three-fold: to review the environmental, health, safety and socio-economic impacts of the proposed Cigar Lake Project; to determine from its review whether the project is acceptable or unacceptable; and to provide full opportunities for public consultation and review. Complete terms of reference for the panel are contained in Appendix B.

2.1 Proposal

The Cigar Lake uranium deposit was discovered in 1981 at the southwestern end of Waterbury Lake, approximately 660 km north of Saskatoon. The Cigar Lake site may be reached by a temporary access road, which joins it to Points North Landing and Provincial Road 905. See Figure 1.

The Cigar Lake ore body contains the equivalent of approximately 385-million pounds of U₃O₈, at an average grade of 9.2 per cent. The proponent, the Cigar Lake Mining Corporation (CLMC), estimates that the reserves will support active mining for over 40 years.

Between 1987 and 1992, CLMC carried out test mining to characterize the deposit and assess proposed mining methods. The site conditions delineated in this way indicated high potential groundwater inflows, unless control procedures were applied. In response, CLMC proposes to freeze the deposit before excavating the ore. Freezing, which in addition to reducing water inflows is expected to stabilize ground conditions and limit radon migration, would be accomplished by circulating refrigerated brine through freeze pipes originating from drifts below the ore body.

Access to the development area underneath the ore body would be through the existing test mine shaft. Two underground levels would be developed, a freeze level approximately 20 to 30 m below the ore body, and a production level between the freeze level and the ore body. The freeze level would consist of parallel drifts from which vertical freeze holes would be drilled upward to about 5 m above the ore body. A brine solution, cooled to -35° C, would then be circulated through vertical tubes, freezing the entire area between the tubes from the freeze drifts to well above the ore body.

Ore would be mined from a production gallery beneath the frozen deposit using non-entry jet boring and boxhole boring methods that would minimize the exposure of miners to radioactive material. The slurry resulting from jet boring would flow through primary and secondary crushing and grinding mills, located underground, before being pumped through cased boreholes to storage tanks on the surface. The cavities remaining after ore removal would be back-filled with a special high-strength concrete mix. About thirty per cent of the mine rock excavated would be used as backfill for the freeze and production levels.

From storage, the ore slurry would be pumped into transportation containers and trucked 80 km to the McClean Lake mill for processing with the Midwest and McClean Lake ores.

Milling of the Cigar Lake ore would involve the use of a process already approved for the McClean Lake project. The McClean Lake mill would be expanded and modified to accommodate the receiving and unloading of the high-grade ore from the Cigar Lake mine site.

The tailings resulting from the milling of the Cigar Lake ore would be neutralized before being thickened to paste consistency, and disposed of subaqueously in the JEB pit at the McClean Lake site.

Over the 40-year operation of the Cigar Lake mine, approximately 1.35-million m³ of waste rock would be excavated to the surface, with most of it having the potential to be acid-generating.

Additional surface facilities needed at the Cigar Lake site to augment the existing test mine facilities would include a freeze plant; a concrete mix plant; additions to the administrative complex; an ore shipping building, which would include a primary water treatment plant; and headframes and hoist buildings for additional shafts. See Figure 2.

The Cigar Lake Project would provide work for approximately 270 persons during the development phase (about 2 years) and employ about 200 workers for the operational phase (about 40 years). An additional 350 persons would be needed for a short time to complete the expansion of the mill facilities at McClean Lake. Also, the employment life of the 132-person workforce at the mill would be extended by 25 years.

2.2 Ownership

The Cigar Lake Mining Corporation is the proponent on behalf of the Cigar Lake Joint Venture. As of August, 1997, the joint venture is comprised of Cameco Corporation (48.750%), Cogema Resources Inc. (36.375%), Idemitsu Uranium Exploration Canada Ltd. (7.875%), TEPCO Resources Inc. (5.000%) and Korea Electric Power Corporation (2.000%).

Figure 1 - Location of the Proposed Cigar Lake Project

Figure 2 - Cigar Lake Mine Site - Surface Facilities Layout

The two major shareholders in the Cigar Lake Joint Venture, Cameco Corporation and Cogema Resources Inc., have been actively involved in the uranium mining industry in Saskatchewan for many years.

Cogema Resources Inc., formerly Cogema Canada Ltd. and Amok Ltd., has been mining uranium in Saskatchewan at its Cluff Lake site since the early 1980s. Currently, Cogema owns and operates the Cluff Lake mine and mill complex. It is also the operator and part owner (70 per cent) of the McClean Lake mine and mill complex, now under construction. In addition, Cogema owns a 16-per-cent interest in the McArthur River Project, and has a 36-per-cent interest in the Cigar Lake Project which is the subject of this report. Cogema also manages uranium production facilities in Wyoming and Texas. Its activities include the decommissioning and reclamation of two open pit mines and mills in Wyoming. The company is involved in exploration activities for uranium in Saskatchewan and the Northwest Territories, and for gold in Nevada. It is considered a dominant player in the world uranium market.

Cameco Corporation was formed in 1988 by a merger of the Saskatchewan Mining Development Corporation and Eldorado Nuclear Limited, a federal Crown corporation. The initial shareholders were the governments of Saskatchewan (61.5 per cent) and Canada (38.5 per cent); however, over 90 per cent of Cameco shares now are privately owned. Currently, Cameco has a partnership interest in four operating or approved uranium mines, at Key Lake (66.67 per cent), Rabbit Lake (66.67 per cent), and McArthur River (55.844 per cent) in Saskatchewan, and at Crow Butte (32.309 per cent) in Nebraska. Although Cameco owns only 48.75 per cent of the proposed Cigar Lake Project, it retains a majority of the voting shares (50.75 per cent). It also has an interest in two gold mines, one at Contact Lake, Saskatchewan (66.67 per cent), and the other at Kumtor in the Republic of Kyrgyzstan (33.33 per cent). [Cameco Corporation, Annual Report, 1995 , pp. 18-19.] In Ontario, Cameco owns and operates uranium refining and conversion facilities at Blind River and Port Hope.

The Cigar Lake test mine has been well managed since its inception. The proposed mine operators have a good record with respect to worker safety and efficient development with minimal environmental damage. The CLMC was also one of the first mines to establish an Advisory Committee, originally with membership from Wollaston Lake, Black Lake, Stony Rapids and Fond du Lac. [Cigar Lake Mining Corporation, Project Proposal , September, 1991, p. 13.]

4.1 The Cigar Lake Mine

It is recommended that approval for mining as described in the EIS be granted, subject to the following condition:

• the proponent must submit to federal and provincial regulators a detailed comparative evaluation of various options for waste rock disposal, including the option that is most advantageous for environmental protection. If no other option presents a clear environmental advantage, the mine waste rock should be disposed of in one of the Sue pits on the McClean Lake site.

Approval for the project should not be granted until a location that provides secure environmental protection has been found for disposal of waste rock.

4.2 The JEB Tailings Management Facility (TMF)

It is recommended that permission be given to use the JEB pit as a disposal facility for tailings produced from the milling of Cigar Lake ore, provided that the following conditions are met:

• it must be demonstrated experimentally that pore-water contaminant concentrations can be maintained at acceptable levels in aged tailings;
• if approval is eventually given to construct a TMF in the JEB pit, the chemical and physical properties of the deposited tailings must be monitored carefully, including periodic assessment of porewater quality;
• Fox Lake must not be used as a mixing zone;
• sediments in Fox Lake must be monitored;
• the more stringent of the Saskatchewan Surface Water Quality Objectives (SSWQO) or the recently amended Canadian Water Quality Guidelines (CWQG) must be used when modelling the expected contamination of Fox Lake;
• a better geotechnical assessment of the underdrain portal should be provided, and design improvements made if required;
• tailings, after consolidation, should not be above the top of the sandstone formation;
• procedures for mitigating all potential unacceptable impacts must be identified before deposition begins. The construction of a hydraulic cage or raising the water level in Fox Lake should be more completely described and approved in principle by appropriate federal and provincial departments before deposition begins;
• the operator of the JEB TMF should be required to demonstrate that it possesses adequate managerial and scientific competence before approval is given to construct and operate this highly dangerous facility;
• the operator of the JEB TMF should demonstrate that it is capable of, and intent upon, giving thoughtful, sincere and professional attention to the concerns of the regulators, Saskatchewan Environment and Resource Management (SERM) and the Atomic Energy Control Board (AECB); and
• arrangements should be made to provide for perpetual monitoring of this and other tailings management facilities, if approval is given. Financial arrangements should be made, prior to approval, for such monitoring. Monitoring should include the participation of local people as described in Section 4.4.

4.3 Long-Term Monitoring

This project, and in particular the JEB Tailings Management Facility, if it is approved, would require long-term monitoring and possible mitigative activities in the future. Arrangements should be made to guarantee that monitoring and any required mitigation could occur without placing a financial burden on future generations. For this reason, we reiterate our previous recommendation for the establishment of a contingency fund to provide for the ongoing costs of long-term monitoring and mitigation, after the responsibility for the sites is returned to the Province.

4.4 The Environmental Quality Committees and the Athabasca Working Group

The Environmental Quality Committees (EQCs) provide a good avenue for encouraging local participation in decisions related to uranium mining activities in northern Saskatchewan. Adequate financial support should be provided to educate and train committee members in the various issues related to uranium mining and milling. The AECB should be more active in its EQC support and participation.

The activities of the Athabasca Working Group (AWG) are to be encouraged. It is important that the mining companies and community representatives meet regularly to discuss issues of common concern; it is also important that the decisions arrived at by the AWG be given more permanent, possibly legal, status.

4.5 Health Studies

We are encouraged by recent initiatives to monitor different aspects of community and worker health, including:

• a study of cumulative effects;
• a study of the possible contamination of country foods;
• a baseline community health status survey; and
• an epidemiological study of the incidence of lung cancer among uranium mine workers.

It is imperative that sufficient funds be made available to ensure that these initiatives are able to continue until their mandates are completed.

4.6 Employment and Business Opportunities

It is recommended that an employment objective for the participation of northerners in the mine workforce be set at a minimum of 50 per cent, and that it be increased by 1 per cent per year until it reaches at least 67 per cent. It is also recommended that an objective of obtaining at least 35 per cent of all required goods and services from northern suppliers be incorporated into the surface lease.

The primary technical challenge addressed in the Cigar Lake EIS is the development of mining methods which allow for the safe extraction of high-grade ore, without excessive environmental damage. During its test mining program, CLMC evaluated various remote-entry mining techniques that would permit safe and efficient mining. Because the ground surrounding the deposit is largely incompetent, creative approaches for improving ground stability were also evaluated. These innovative approaches have enhanced the technical capabilities of the industry to mine similar problematic ores.

This chapter provides a brief description of the mining methods that the CLMC proposes to use, and the environmental and safety concerns associated with them.

5.1 Mining Methods

The Cigar Lake ore body is located between 410 and 450 m below the surface in very incompetent ground at the unconformity between metamorphic basement rocks and the overlying sandstone rocks. Ground freezing, originating from drifts in basement rock below the ore body, would be used to enhance the competence of the rock associated with the ore, and to restrict water flow into and through the mine excavations. Mining by non-entry methods would be controlled from production drifts, also located below the ore body.

The underground facilities of the mine would be serviced by three shafts. The existing test mine shaft would provide access to the freeze and production drifts. Two additional shafts, through which ventilating air would be exhausted and emergency egress could occur, would be developed in the future.

The mining methods proposed by CLMC have been designed to reduce water inflow, preclude direct exposure of workers to the high-grade uranium ore body, and improve rock support capabilities. The EIS describes mining methods compatible with the variable geometry of the Cigar Lake ore deposit, and the methods that would be required to control water inflow.

The techniques proposed to mine the ore are boxhole boring and jet boring, both of which are remote, non-entry mining methods. Ore-handling processes, including transport of ore from the excavation sites, crushing of the ore on the production level, and pumping of ore slurry to surface, would take place in shielded conduits that protect workers from radiation at all times. The intent of the proposed mining and ore-handling techniques is to minimize worker exposure to the high-grade ore being recovered.

As mining progresses, ore and waste excavations would be backfilled using a high-strength concrete mix designed to cure under freezing conditions. This concrete fill material would provide structural support within the ore body and limit the flow of water through the mining horizon as ore extraction proceeds.

For drift development, the CLMC plans to use conventional drilling and blasting methods, as well as conventional ground support techniques, where the ground is competent. Where rock is less competent, CLMC proposes to use mechanized procedures, such as the New Austrian Tunnelling Method (NATM) and the Shielded Mine Development System (SMDS), for development.

5.1.1 The New Austrian Tunnelling Method and the Shielded Mine Development System

From information collected during underground test mining and diamond drilling from surface, CLMC has identified eight distinct geotechnical zones within and about the ore body. Three of these zones exhibit rock mass conditions that are characterized as being fair to extremely poor, and include significant zones of incompetent rock, squeezing clay, unconsolidated sand and friable sandstone. Poor rock mass conditions are typical within the altered basement rock below the Cigar Lake ore body where the proponent plans to develop the freeze and production drifts. Excavations created in these rock zones would require substantial support during and after excavation, and could not be developed effectively using traditional drilling and blasting techniques. [ The Cigar Lake Project, Response to Request for Additional Information, Cigar Lake Mining Corporation, March, 1996, pp. 2-5 to 2-7 and Figure 2.1.1.5.]

Due to the very poor ground conditions below the orebody, in which the conventional drill and blast method allowed limited success, it was necessary to introduce the New Austrian Tunnelling Method.

B. Schmitke, Cigar Lake Mining Corporation, Transcript of Cigar Lake Public Hearings, Saskatoon, Saskatchewan, September 10, 1996, p. 2.

Based on test mine experience, the proponent plans to use the NATM and SMDS techniques for excavation where the ground is not sufficiently competent to permit conventional mining operations. Both techniques employ the principles of mechanized rock excavation within shielded covers, including the pre-installation of partial support and the rapid deployment of long-term rock support after excavation. These techniques have been designed to increase worker safety during rock excavation, and to reduce the time necessary to place rock support following excavation. Although not technologically innovative in terms of rock excavation science, the proposed methods are considered state-of-the-art in their ability to provide safe and effective mine development and support. CLMC would use the NATM technique in approximately 10 per cent, the SMDS technique for about 60 per cent, and conventional techniques for the remaining 30 per cent of underground excavations.

All excavations would be lined with concrete or shotcrete for rock support. To reduce radiation exposure, the excavations would be sloped to convey seepage water and inadvertent ore slurry spills away from workers.

5.1.2 Ground Freezing

From test mine data, the ore body is known to exhibit poor to fair rock mass quality, low strength, high porosity and high water saturation characteristics. Groundwater sampling from drill holes in the sandstone and altered sandstone formations indicated the potential for groundwater inflows of 2700 m³/hr during mining. Within basement rocks, low hydraulic conductivities were found, yielding significantly lower water inflow rates. CLMC expressed several concerns for mining within the ore body, including:

• the support of the weak rock associated with the ore body;
• the potential for a large inrush of water while mining the ore; and
• the containment of the ore cuttings and any associated water to minimize the potential for radiation exposure. [ The Cigar Lake Project Environmental Impact Statement, Main Document, Cigar Lake Mining Corporation, July, 1995, p. 3-32.]

During test mining, CLMC evaluated the ability of various techniques to address these concerns. Conventional rock excavation and support techniques, including grouting, proved to be less effective than ground freezing for improving mine stability and limiting the inflow of radon-laden water. In contrast, rock preconditioning, using curtain grouting and ground freezing, reduced inflow rates to approximately 20 m³/hr during test mining. Based on these positive test mine results and the knowledge that ground freezing applications have been used as standard operating procedures in many mines, including potash operations in southern Saskatchewan, CLMC proposes to apply this technology during mine development.

Ground freezing would be achieved by circulating a cold brine solution through freeze pipes drilled upwards through the ore from horizontal galleries excavated below the ore body. It is anticipated that the ore body would be frozen over the entire width and height of the ore zone. In addition, rock zones lying between the freeze level and the ore body would be frozen and therefore structurally reinforced.

The containment of ore cuttings and associated water would be addressed by installation of a preventer on the jet boring machine. This preventer would divert broken ore and water away from workers and into a crusher. [B. Schmitke, Presentation to Public Hearings, Saskatoon, Saskatchewan, September 10, 1996, pp. 2 and 9.]

The presence of approximately 88,000 m of exploration drill holes, [The Cigar Lake Environmental Impact Statement, Main Document, Cigar Lake Mining corporation, July, 1995, p. 3-5.] and the possible addition of 70,000 m more (30,000 m required for the complete delineation of the ore body, [Ibid, p. 3-18.] and 40,000 m of geotechnical core and rotary drilling [Ibid, p. 3-24.] ) are cause for concern. A significant number of the completed and planned drill holes encroach upon the ore zones, providing pathways for radon-laden water or air into occupied excavations. Such flow could occur wherever ungrouted holes are intercepted or ground freezing is incomplete. To protect against the intrusion of water or air, all bore holes that intersect underground workings should be sealed systematically. The proponent should not rely only on ground freezing or area grouting to seal the bore holes.

5.1.3 Jet Boring

Based on test mining results, CLMC proposes to use jet boring as its primary mining method. Ore removal by jet boring involves insertion of a jetting head through a hole that has been drilled from the production drift to the top of the ore body. Water under high pressure is then pumped through the jet while the head is rotated, cutting the frozen ore and washing it down the hole. The jet is slowly lowered, eventually creating a cylindrical excavation in the ore about 2 m in diameter. The broken ore and water washing down the hole would be diverted to a crusher by use of a preventer. In this way, workers in the production drift are protected from direct contact with the highly radioactive ore. Test mine experience indicates that this process will recover about 95 per cent of the ore. [The Cigar Lake Project, Response to Request for Additional Information, Cigar Lake Mining Corporation, March, 1996, Table 2.3.1.1.]

After ore extraction, the bore holes would be filled with a high-strength concrete mixture to maintain the structural integrity of the frozen ore zone during mining. At the conclusion of mining, and after thawing of the rock, the competence of these zones is expected to be better than that of the originally intact ore. Replacement of weak, friable and saturated ore by high-strength concrete should reinforce the existing rock structure.

5.1.4 Boxhole Boring

The proposed boxhole boring technique, which would be used to extract about 5 per cent of the ore, requires dry excavation of holes 1.5 m in diameter. Drilled vertically upward from the production drifts, the holes would pass through inert basement rock and into the ore above. The extraction of ore and accompanying waste rock would occur solely through the action of drilling, without the use of explosives to fracture the rock. As the rock is drilled, it would fall through the excavated borehole into sealed chutes and containers, located within the production drifts.

The mining industry has safely used similar remotely-operated boxhole boring techniques for decades. At Cigar Lake, however, it would be necessary to modify boxhole boring by fully enclosing the extraction chutes, and to provide remote transport of slurried ore to surface. This approach is required to protect workers on the production levels from contact with the highly radioactive ore. Following ore extraction, the relatively small boxhole excavations would be rapidly backfilled with cement to maintain rock stability.

Although boxhole boring was successfully demonstrated during underground mining trials at the Cigar Lake test mine, it would be a secondary option for mining the ore body. It is less attractive than jet boring because of potential dust problems and excessive waste rock generation.

5.2 Liquid Effluent

5.2.1 Water Conservation

As noted in Section 5.1.2, the application of grouting and ground freezing is expected to substantially reduce the flow of water into the mine. Residual inflow is expected to occur at a rate of 30 m³/hr. To minimize the amount of mine water requiring treatment, CLMC plans to recirculate process water at the rate of approximately 20 m³/hr into the underground jet boring operations. This recirculated volume would account for approximately 40 per cent of the total average water volume necessary for jet boring and slurry preparation, and would reduce effluent treatment requirements accordingly.

5.2.2 Primary Treatment

Any process water which is not reused would be treated in the primary water treatment facility on surface. The primary treatment facility, which would process contaminated mine water, surface runoff and recycled water, is designed to handle water at an average rate of 100 m³/hr. However, under conditions of excessive inflow, this facility could be operated at a contingency rate of 700 m³/hr.

5.2.3 Secondary Treatment

A secondary water treatment facility would be used for final polishing of effluent from the primary treatment facility, as well as for surface runoff water, prior to release into the environment. Under mine operating conditions, approximately 39.5 m³/hr of primary treatment effluent would flow through the secondary treatment facility, which would have the capability to handle quantities up to 825 m³/hr. Final release of effluent to the environment is planned at the rate of approximately 28.5 m³/hr. Release would be into a muskeg area located upstream from Aline Lake. [ The Cigar Lake Project Environmental Impact Statement, Response to Request for Additional Information, Cigar Lake Mining Corporation, March, 1996, Figure 1.3.1.1.]

Following secondary treatment, it is predicted that the effluent will meet Saskatchewan Surface Water Quality Objectives.

5.2.4 Modelling of Environmental Loadings

The proponent reported the results of modelling exercises that it used to predict environmental loadings due to effluent release for average- and worst-case test mine conditions. For the worst-case scenario, modelling predicted that the contaminant concentrations in Aline Lake would not exceed Saskatchewan Surface Water Quality Objectives (SSWQO) during the proposed 41-year operating life of the Cigar Lake mine. [The Cigar Lake Project, Response to Request for Additional Information, Cigar Lake Mining Corporation, March, 1996, pp. 1-53 and 1-54.] SERM also reported modelling studies, using conservative arsenic effluent concentrations, which indicated that water quality conditions within Aline Lake would be at or below the limits of the SSWQO.

Should mine water concentrations of heavy metals, specifically arsenic and molybdenum, prove to be higher than predicted, CLMC has proposed contingency treatment plans. Such remediation would involve primary treatment to precipitate contaminants within settling ponds, prior to secondary water treatment.

CLMC should be required to monitor all toxic chemicals and heavy metal contaminants (not just arsenic and molybdenum), which might impact downstream water quality conditions. Site-specific water quality objectives should be developed for the Cigar Lake site and, if contaminant concentrations are found to be above those objectives, appropriate mitigative measures should be implemented.

5.2.5 The Need for Additional Research

The mine water treatment capabilities, as described in the EIS, appear to be adequate. We concur with the conclusions stated by Saskatchewan Environment and Resource Management:

Mine water treatment at the Cigar Lake site would be conducted using existing and proven treatment technologies. Treatment technologies are such that all metal contaminants and radionuclides can be removed to acceptable levels in the effluents. [Saskatchewan Environment and Resource Management, Submission to Cigar Lake Public Hearings, Regina, Saskatchewan, September 4, 1996, pp. 21-22.]

We also agree with SERM's conclusion that additional research is required into methods that could be used to further reduce the environmental impacts resulting from the release of effluent at the Cigar Lake mine site. The current practices of aeration and chlorination in underground sumps to disperse radon and reduce lead-210 dissolution are the minimal pretreatment processes which should occur. As improved treatment technologies become available, they should be incorporated expeditiously.

In addition, research should be done to identify appropriate site-specific water quality objectives. The SSWQO currently in use were developed primarily for the southern part of the province where the total dissolved solids in natural water systems are typically much higher than in northern Saskatchewan. Site-specific objectives should reflect this difference in existing natural conditions.

5.3 Conclusions and Recommendations

The panel is satisfied that the proponent has adequately addressed the technical challenges of mining the high-grade Cigar Lake ore. Non-entry mining methods would provide protection from radiation exposure in three ways: both jet boring and boxhole boring methods, controlled from production galleries separated from the ore body by about 15 m of rock, would shield workers from the highly radioactive ore body; the use of sealed conduits for transporting slurried ore within the mine and to surface would reduce the extent of radiation exposure from the mined ore; and, ground freezing, limiting the incursion of radioactive water flows into occupied mine excavations, would protect workers from contact with radon and radon progeny.

All exploration, development and production drill holes should be sealed to prevent inflow of potentially contaminated air or water into under-ground work sites.

Site-specific water quality objectives reflecting natural conditions in northern water bodies should be developed for the Cigar Lake mine. CLMC should develop monitoring and treatment contingencies for all chemical and heavy metal contaminants (not just arsenic and molybdenum) which may potentially impact downstream water quality conditions. If monitoring of effluent indicates concentrations above the site-specific water quality objectives, mitigative measures should be implemented.

Additional research is recommended for the development of methods to further reduce the environmental impacts resulting from effluent releases.

The environmental concerns resulting from the production of mine waste rock vary significantly depending on its characterization, the volume produced and the method of its disposal. Some of the options for disposal of waste rock are: storage as a surface pile, burial in a water body, return to the excavation from which it came, or use as construction aggregate.

Normally, mine waste rock is classified as either clean waste or special waste, depending on its mineral content and its propensity to be acid-generating. The Cigar Lake Mining Corporation (CLMC) proposes a management strategy which would assume that all waste rock produced during mining operations, estimated at 2.6 million tonnes, would be designated and handled as special waste. Clean sandstone waste produced during shaft sinking would be used for road construction and other civil engineering requirements. [The Cigar Lake Environmental Impact Statement, Additional Information , Cigar Lake Mining Corporation, March 1996, p. 1-71.]

6.1 Disposal Options

Deposition of the special waste in a manner which protects the environment would require identification of an appropriate method and location for disposal.

The initial option in CLMC's management strategy is to retain as much waste rock as possible underground and use it to backfill the mined-out drifts and galleries. It is estimated that about 30 per cent of the waste could be handled in this way. [Ibid, p. 1-70.] This option is to be encouraged and maximized; however, it is evident that most of the waste rock would require disposal by other means.

A primary concern with surface storage is that contaminants associated with the rock might be mobilized either through surface runoff or by the infiltration of precipitation into the waste rock pile. If water enters the pile, it has the potential to produce a leachate by dissolving heavy metal contaminants within the rock. This leachate could then enter the groundwater or be discharged to the surface environment, causing significant environmental impacts.

There is a particular environmental concern with much of Cigar Lake's waste rock because it contains relatively high levels of sulphides along with significant amounts of arsenic and nickel. When exposed to precipitation and oxygen, sulphide minerals produce acid which increases the leaching of other contaminants from the waste rock. Acid generation occurs readily in mineralized waste piles because the sulphides within the rock are exposed to both oxygen and water when the rock is broken and brought to surface. Under certain conditions, sulphide oxidation is also enhanced by the presence of autotrophic bacteria. [L.M. Broughton, R.W. Chambers and A. Mac G. Robertson, Mine Rock Guidelines, Design and Control of Drainage Water Quality, Saskatchewan Environment and Public Safety, April 1992, Chapter 3.] If unmitigated, acid production would continue until all available sulphide minerals were depleted. Depending on the characteristics of the waste rock pile, acid generation and the associated dissolution of metals, such as arsenic and nickel, could threaten the receiving environment for many decades.

Methods to reduce or limit the potential for acid generation are well understood. The most effective method is to limit the amount of oxygen available for the production of acidic leachate. A proven technique to ensure that potentially acid-generating (PAG) waste rock is not exposed to oxygen for an extended length of time is to place it below a water cover. [Ibid, Chapter 6.] Similar results could be achieved with placement in a mined-out pit, under a cap of clean waste rock and till.

The diffusion coefficient for oxygen in water is nearly 100,000 times less than the diffusion coefficient for oxygen in air. For this reason, less than a metre of relatively stagnant, oxygen-depleted water will reduce the oxidation rate of submerged sulphide minerals to almost zero. Such a management strategy has been well researched and has received support from the regulatory agencies:

• The AECB supports the concept that, with appropriate controls, underwater or in-pit disposal of potentially acid generating waste rock is preferable to surface stockpiling. [S. Isanen, Atomic Energy Control Board, Transcript of the McArthur River and Cigar Lake Public Hearings, Saskatoon, September 18, 1996, p. 37.]
• Sub-aqueous disposal is accepted by the Department as a technique for dealing with PAG waste rock that would have potential impacts, if simply left on the surface. [R. Sentis, Saskatchewan Environment and Resource Management, Transcript of the McArthur River and Cigar Lake Public Hearings Regina, September 4, 1996, p. 54.]

However, for this strategy to be effective over time, the water cover must be permanent. If PAG waste rock is exposed at any time in the future, acid generation would begin and the associated negative environmental impacts caused by the contaminated leachate would occur.

The option for disposal initially proposed by CLMC in its EIS was subaqueous disposal of the PAG waste rock in Bizarre Lake, a small but relatively deep lake located approximately 3 kilometres northeast of the mine site. However, Bizarre Lake contains a fish population, including lake trout, that is duplicated by only one other lake in the region, Waterbury Lake. During the review of the Cigar Lake EIS, it was evident that some government agencies, departments and members of the public were concerned about the impact that subaqueous disposal of the waste rock would have on Bizarre Lake, particularly on its lake trout population:

• Cigar Lake Mining Corporation's proposal to treat Bizarre Lake as a waste management facility, is completely unacceptable. Bizarre Lake is a deep, reasonably ecologically diverse lake, with a good lake trout population. [P. Prebble, Saskatchewan Environmental Society, Transcript of the McArthur River and Cigar Lake Public Hearings, Saskatoon, Saskatchewan, September 16, 1996, p. 159.]
• With respect to its location, the size, the greater-than-average mean depth, and fish species assemblage in Bizarre Lake render it atypical when compared with similar sized lakes within this part of northern Saskatchewan. [B. Fallis, Department of Fisheries and Oceans, Transcript of the McArthur River and Cigar Lake Public Hearings, Saskatoon. Saskatchewan, September 18, 1996, p. 145.]

It is evident that CLMC has not justified the selection of Bizarre Lake as the most appropriate location for disposal of the waste rock generated from mining the Cigar Lake ore body. Destruction of the fish habitat of Bizarre Lake for the reasons given by the proponent is unacceptable. For these reasons, Cigar Lake has withdrawn its proposal to use Bizarre Lake for waste rock disposal.

Cigar Lake has heard the clear and firm positions expressed by both federal and provincial agencies...the selection of Bizarre Lake is unacceptable...Cigar Lake Mining Corporation are now prepared to respond to the agency's views and adopt Lake 497 as the mine rock disposal option.

G. Acott, Cigar Lake Mining Corporation Transcript of the McArthur River and Cigar Lake Public Hearings, Saskatoon, Saskatchewan, September 18, 1996, p. 13.

Two additional options for subaqueous disposal are identified and briefly discussed in the EIS: disposal in Lake 497, a smaller, less ecologically diverse lake in the vicinity of the mine; and disposal in the Sue C pit, located at the McClean Lake mine site, which is owned and operated by Cogema Resources Inc. Both the Sue C pit and Lake 497 may be viable options, but both must be subjected to a detailed examination before a decision that minimizes future uncertainties can be made.

Use of the Sue pits at McClean Lake for disposal of PAG waste rock provides an additional decommissioning option - that of covering the special waste with several metres of clean waste capped by a metre or two of till. Such an approach would return the area to approximately the same condition as existed prior to mine development and thereby provide compliance with one of the fundamental decommissioning objectives, as discussed in Chapter 10. If no other alternative presents a clear environmental advantage, this would be our preferred option.

Sufficient site-specific information to fully assess the appropriateness of these two options for the disposal of the Cigar Lake waste rock is currently not available. From a consideration of the limited information available with respect to their ability to provide environmental protection, it would seem that both options have advantages and disadvantages which would require intensive investigation. For example, selection of the Lake 497 option could not be considered without collection and analysis of more detailed baseline data for the lake and downstream water bodies. It must also be shown capable of maintaining a permanent water cover of sufficient depth over the deposited waste rock to ensure long-term environmental protection. The Sue C option, on the other hand, could not be selected without additional knowledge of the geology and hydrogeology of this yet to be constructed pit. The potential for contaminant migration in the ground water would also have to be carefully modelled before Sue C could be considered to be a viable option. If neither of these options proves to be acceptable, other solutions to the Cigar Lake waste rock disposal problem would have to be considered. Approval for the project should not be granted until a location that provides secure environmental protection has been found.

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.

Before approval to operate can be granted for the Cigar Lake Project, CLMC should submit a detailed report to the provincial and federal regulators, giving a comprehensive evaluation of its waste rock disposal options and available locations. The report should indicate a preferred option, supported by a thorough justification. Two of the options evaluated should be the use of the Sue C pit, and the use of subaqueous disposal in a water body such as Lake 497.

We believe that if the Cigar Lake Mine development is to go ahead, the option of using the Sue C pit for waste rock disposal should be further examined.

A. Coxworth, Saskatchewan Environment Society, Transcript of McArthur River and Cigar Lake Public Hearings, Saskatoon, Saskatchewan, September 19, 1996, p. 69.

In selecting the preferred disposal option, the wishes of the traditional users of the land in the area should be respected. Before a disposal site is selected, CLMC and the regulators should consult the impact commu-nities and give them an opportunity to assess the potential benefits and liabilities associated with the options being considered. This consultation could take place through the Environmental Quality Committees. The wishes of the communities should be integrated into the final decision-making process, and documented as part of the justification for the preferred option.

Tables 6.1 and 6.2 provide a list of issues associated with lake and till-capped pit disposal that should be considered during site selection. The list is not intended to be exhaustive; the proponent, the regulatory agencies and the public may suggest additional issues judged to be significant and relevant. Economic considerations should not play a significant role in the decision with respect to the final disposal option. Any funds spent on transporting and disposing of the waste rock will be relatively insignificant when compared to the overall value of the project.

The president of Cigar Lake Mining commented--gave a figure of $10 million as a number to the cost to transport the waste rock to the Sue C pit and he looked at that as a loss to the company and the Saskatchewan government, but you have to ask yourself where would that $10 million be spent. It would be spent hiring northern trucking firms and northern people to do that job. So you would be paying northern people to protect the northern environment. And I think $10 million to save a lake from destruction is worth it.

N. Sinclair, Transcript of McArthur River and Cigar Lake Public Hearings, Saskatoon, Saskatchewan, September 18, 1996, p. 160.

After a detailed evaluation, if no other option presents a clear environmental advantage over the others, it is recommended that the proponent be required to dispose of the Cigar Lake mine waste rock in one of the Sue pits at McClean Lake. This recommendation is based on the principle that, where possible, waste rock should be disposed of in an area already disturbed by mining activity rather than in an undisturbed area. In addition, refilling of a mined-out pit has the added advantage of being a preferred option for the decommissioning of the Sue pits.

6.2 Conclusion and Recommendation

The proponent must submit to federal and provincial regulators a detailed comparative evaluation of various options for waste rock disposal, indicating the option which is the most advantageous for environmental protection. The options evaluated must include the Sue pits and Lake 497. Approval for the project should not be granted until a location that provides secure environmental protection has been found.

If no other option presents a clear environmental advantage, it is recommended that the proponents be required to dispose of Cigar Lake waste rock in one of the Sue pits at McClean Lake, and that the disposal site be decommissioned by filling the remainder of the pit with several metres of clean waste, capped by one or two metres of till.

When the panel began its work in 1991, the operators of the McClean Lake, Cigar Lake and Midwest Joint Venture (MJV) projects each proposed to construct milling and tailings disposal facilities adjacent to their mines. McClean Lake reported that, "the mill will be constructed near the JEB site", and that it had selected "the award winning Pervious Surround Method" for tailings disposal in the JEB pit. [The McClean Lake Project, Executive Summary Total Minatco Ltd., 1991, pp. 6-8.] The MJV documents indicated that, "The mill site on the east side of Mink Arm was selected for its comparatively level ground and proximity to the orebody", and that, "The tailings disposal pit will be excavated into the Athabasca sandstone bedrock below the water table". [Environmental Impact Statement, Executive Summary, Midwest Joint Venture, 1991, pp. 11-12 and inserts.] The Cigar Lake Mining Corporation presented plans that included a mill location west of the headframe and a tailings (waste management) area south-east of Abysmal Lake in the Longyear/Seru Bay watershed. [Project Proposal, Cigar Lake Mining Corporation, September, 1991, Figures G300-018 and G300-013A.]

After extensive scoping, the panel published Guidelines in September 1992 that included the requirement for the proponents to, "Compare the relative advantages and disadvantages of all mines milling at one central site, chosen for its environmental suitability, versus milling at several local sites". [D.G. Lee, J.F. Archibald, J. Dantouze, R. Neal and A. Yassi, Guidelines for the Preparation of Environmental Impact Statements and Government Information Requests for the Cigar Lake and McArthur River Projects, September, 1992, p. 24.] In response to the Guidelines, the Cigar Lake Project EIS contains a discussion of the advantages and disadvantages of on-site and off-site (collective) milling at the McClean Lake mill. [The Cigar Lake Project Environmental Impact Statement, Main Document, Cigar Lake Mining Corporation, July, 1995, pp. 2-2 to 2 - 5.] Two main advantages are noted. First, reduced surface damage at the Cigar Lake site would allow it to be decommissioned, leaving only a small environmental footprint. It is argued that expansion of an existing mill to accommodate the Cigar Lake ore would cause less environmental disruption, in total, than the construction of a second, stand-alone mill at the mine site, as originally proposed. Secondly, the companies involved would benefit financially and be able to return higher royalties to the people of Canada. The EIS notes that an enlarged joint mill would require less capital investment, in total, and that operating costs would "benefit from the economy of scale obtained in milling a larger mill feed". [Ibid.]

At least three disadvantages to off-site milling also require consideration. First, it would be necessary to transport ore over public and private roads, causing the environmental impacts associated with road construction and maintenance. Increased traffic would also create more dust which would, in turn, impact the local environment and make road travel less safe for other purposes. In addition, the danger of ore spills during transport would pose a risk to the environment that could be minimized only by the increased capital and operational expenses associated with the manufacture and use of fail-safe trucks and transport vessels.

Secondly, off-site milling would decrease employment opportunities at the Cigar Lake site. Such a decrease would be partly offset by the need for more truck drivers and an increase in the workforce at the enlarged mill. It would also ensure employment at the mill over a longer time period.

Thirdly, the Cigar Lake EIS points out that combined milling with other projects "raises many business issues resulting from various aspects such as ownership, operatorship, commercial terms and long-term liability, just to mention a few" [Ibid .] Obviously, there would be new administrative problems to deal with when two or more competitors share the same facility.

The disadvantage that has the greatest possibility for interference with the current arrangement is the potential for disagreement among the partners involved in the JEB mill and tailings management facility. As noted in the Cigar Lake EIS, business arrangements at this site are complex. If the proposed management arrangements should prove to be unworkable, resulting discord could compromise many of the health, safety, environmental and economic benefits that would otherwise flow from the current proposal. The governments could then expect, at some time in the future, to be faced with a request from one or more of the companies to establish another site for milling.

The panel is not privy to the internal contracts and legal arrangements that would govern the joint operation of the mill and tailings management facility. Therefore, we are recommending that the appropriate government agencies carefully examine these arrangements to ensure that they are workable and sufficiently binding before giving approval to the Cigar Lake project. If the proposed arrangement is accepted, it should be with the clearly stated condition that the governments will not entertain requests from the companies for the establishment of separate milling sites at a future date without a full public review.

7.1 The JEB Mill

Since the JEB mill was reviewed as part of a previous panel report, [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.] and since it has already received ministerial approval, [Honourable Bernhard H. Wiens, Ministerial Decision Under the Environmental Assessment Act, McClean Lake Uranium Development, Province of Saskatchewan, December 22, 1993.] only a brief summary of the milling process will be given here.

On December 22, 1993, ministerial approval was given to construct a mill for refining ore from the JEB, Sue A, Sue B, Sue C and McClean Lake mines at the McClean Lake site. This approval contained a requirement to conduct research into methods that could be employed to reduce process chemicals and optimize contaminated water treatment, with the overall objective of reducing environmental loadings. As a consequence of this research, Cogema proposed changing from strong acid stripping to ammonium sulphate stripping. Test work showed that, by use of this approach, the volume of tailings produced could be reduced by 28 per cent, while holding ammonia concentrations in the effluent at an acceptable level.

The EIS submitted by Cigar Lake [The Cigar Lake Project Environmental Impact Statement, Main Document, Cigar Lake Mining Corporation, July, 1995, pp. 11-9 to 11-21.] contains a description of the various processes that will occur in the mill: receiving solid mine ore, grinding, two-stage atmospheric leaching, counter current decantation, pregnant solution clarification, solvent extraction, stripping with ammonium sulphate, molybdenum removal, precipitation of ammonium diuranate, barren strip solution clarification, crystallization of ammonium sulphate, and neutralization of the tailings. This process produces two commercial products, ammonium diuranate and ammonium sulphate. The former can be calcinated to produce yellowcake (U₃O₈); the latter can be sold for fertilizer.

In order to accommodate slurried Cigar Lake ore, produced as described in Section 5.1, the mill design would require three main modifications:

• the building of a new facility to receive and unload ore slurry;
• the enhancement of mill capacity; and
• the modification of the tailings preparation circuit to produce neutralized paste tailings. [Ibid, pp. 12-1 to 12-16.]

The new receiving facility would be required because ore from the Cigar Lake mine would be produced and transported as a slurry, whereas the currently approved mill is equipped only to receive solid ore. Paste tailings must be produced because subaqueous disposal is proposed in the JEB pit. Highly radioactive tailings, such as those produced from the Cigar Lake ore, can be placed more safely in the pit under a layer of water.

The two main waste products produced in this process would be contaminated water and tailings. The contaminated water would be recycled and reused, or sent to the water treatment plant. The tailings would be sent by pipeline to the mined-out JEB pit for permanent in-pit disposal as described in the next section.

7.2 The JEB Tailings Management Facility

The greatest environmental risks associated with the Cigar Lake project are related to the method selected for tailings disposal. Because of the large volume of tailings produced, it is not practical for mines to consider deep geological deposition, as recently proposed for high-level nuclear reactor wastes. [Environmental Impact Statement on the Concept for Disposal of Canada's Nuclear Fuel Waste, Atomic Energy of Canada Limited Report, C.O.G.-93-1, 1994.] It is of interest, therefore, to note a report which indicates that mill tailings are more toxic in the long term than are high-level wastes. [J.D. Bredehoeft, A.W. England, D.B. Stewart, N.J. Trask and I.J. Winograd, Geologic Disposal of High-Level Radioactive Wastes -- Earth-Science Perspectives: A summary of factors and processes that must be understood for the safe containment of high-level radioactive waste, Geological Survey Circular 779, 1978, p. 10.] For this reason, it is essential that the method proposed for tailings disposal be subjected to careful scrutiny before implementation is approved.

...the hazard from uranium mill tailings which although more than an order of magnitude more toxic than high level waste, have customarily been treated in a much more cursory fashion.

Dr. G. Edwards, Transcript of Supplementary Public Hearings for Midwest and Cigar Lake, La Ronge, Saskatchewan, August 28, 1997, p. 69.

CLMC, through an agreement with Cogema Resources Inc., proposes to custom mill its ore at the JEB mill and to use the mined-out JEB pit at McClean Lake for a disposal facility.

Various configurations (engineered pervious surround, partial engineered pervious surround and natural surround) were considered for the conversion of this pit into a storage facility. After modelling the impacts associated with each configuration, both the proponents and the Atomic Energy Control Board have concluded that the natural surround would provide the best environmental protection.

Successful application of this technology requires that the tailings be produced and deposited in such a way that they consolidate over time to give a material that has a hydraulic conductivity at least ten times less than that of the surrounding host rock. The essential difference between this approach and the technology pioneered at the Rabbit Lake in-pit TMF is that it is the tailings, rather than the surround, which would be engineered to produce the required difference in hydraulic conductivity. Several potential advantages of this approach, as noted by the proponents, are described in the following paragraphs:

• Natural surround technology allows the tailings to be deposited under water. The ability to use subaqueous deposition is important for tailings produced from high grade ore because it provides for greater worker protection. As described in the EIS, [The Midwest Project Environmental Impact Statement, Main Document, Cogema Resources Inc., February, 1996, pp. 3-60 to 3 - 81.] deposition of the tailings under a few metres of water protects the people working around the pit from exposure to radiation. It is, therefore, proposed that the tailings would be laid down, using a tremie pipe, [See Figure 3.] under a cover of water that would be deep enough to absorb most of the radiation emanating from the deposit.
• Subaqueous deposition would also prevent the formation of ice in the tailings before they had consolidated.
• The approach proposed for the JEB pit would allow the tailings produced from the milling of the ore from several mines (JEB, McClean, Sue A, Sue B, Sue C, Midwest and Cigar Lake) to be deposited in a single pit, thereby decreasing the number of sites requiring long-term monitoring.
• The use of a natural surround would permit the maximum quantity of tailings to be placed in the pit; i.e., the amount of environmental disturbance associated with pit construction, per tonne of tailings stored, would be minimized.
• The use of natural surround technology would avoid the use of engineered barriers, such as dams or liners, which might fail in the long term.
• Eventual capping of the pit with several metres of rock and till would avoid the weathering problems that are likely to compromise aboveground storage facilities in the long term. Capping the pit would also protect wildlife and humans from direct exposure in the postdecommissioning era.
• Tailings deposited in a pit, below ground level, would be protected when glaciers from the next ice age scarify the landscape of northern Saskatchewan.

Despite these potential advantages, many concerns associated with the use of the proposed tailings management facility were raised during the hearings. Among these are the closeness of the JEB pit to Fox Lake (about 125 m) and the failure of Cogema to provide convincing evidence that the lake is not likely to become contaminated in the long-term. Modelling studies indicate a good possibility that arsenic levels, for example, could eventually exceed both Saskatchewan Surface Water Quality Objectives (SSWQO) and Canadian Water Quality Guidelines (CWQG) in Fox Lake.

Figure 3 - JEB TMF - Subaqueous Tailings Disposal

Part of the uncertainty relates to the predicted concentrations of arsenic in the porewater of aged tailings. Estimates for the arsenic source term ranged from as low as 1 mg/L or less, to as high as 100 mg/L or more. Consultants with distinguished credentials, employed by Cogema, suggested theoretical ways of reducing porewater concentrations by creating conditions in the tailings pit that would result in the formation of secondary minerals. [D. Langmuir, Transcript of Supplementary Public Hearings for Midwest and Cigar Lake, La Ronge, Saskatchewan, August 26, 1997, p. 39-47.] On the other hand, an engineering firm reviewed published data and experimental results from existing tailings facilities which indicated that arsenic concentrations in the porewater, instead of decreasing with time, have actually increased at a rate of about 500 per cent per year. [R.C. Swider, The Cigar Lake and Midwest Projects Tailings Disposal, Richard C. Swider Consulting Engineers Limited, Toronto, Ontario, August 21, 1997, p. 23.] When the hearings closed on August 28, 1997, the issue of the value to be assigned to the arsenic source term remained unresolved. It is clear, however, that a licence should not be given to use the JEB pit as a TMF until it has been demonstrated that arsenic and other contaminants in the porewater can be maintained at levels sufficiently low to minimize the chance that Fox Lake would be polluted in the long term.

It is at this point that the regulatory process must take over from the panel process. We find the concept of in-pit tailings disposal using a natural surround to be acceptable, but we are not able to assess all of the required site-specific conditions. In fact, we believe that our involvement at that level would be inappropriate. We are, therefore, making a favourable recommendation with respect to the concept of using the JEB pit as a TMF, but wish to temper that recommendation by attaching the following list of site-specific conditions that must be dealt with satisfactorily before a licence is given: [As mentioned elsewhere in this report, we have confidence in the regulators ability to undertake this task, provided they are given adequate resources to do so.]

• Before the JEB pit is approved for deposition of tailings from Cigar Lake ore, the operator must demonstrate, using actual experimental data from aged tailings, that porewater contaminant concentrations can be controlled at acceptable levels. Theoretical solutions should not be accepted in lieu of experimental data for these purposes. The chemistry of tailings depositories is so complex that theories can be used only as a rough guide for the design of processes.

Well, in fact, we did not carry out leaching tests because when you have to carry out some tests, you have to be very cautious, you know.

M. Roche, Cogema Resources Inc., Transcript of Supplementary Public Hearings for Midwest and Cigar Lake, La Ronge, Saskatchewan, August 28, 1997, p. 23.

• If approval is given subsequent to the completion of the specified research, the contents of the pit should be monitored carefully to determine if the concentration of contaminants in the porewater is increasing or decreasing over time. We suggest a detailed survey every five years to examine pore-water chemistry and to check for the development of secondary minerals. If conditions can be found which promote formation of secondary minerals, as suggested during the hearings, the pit would gradually begin to resemble a thermodynamically stable geological deposit. On the other hand, if porewater contaminant concentrations are found to increase with time, as predicted from the data presented by Richard Swider, deposition should cease. Licence approvals should continue to be for a limited time only. Renewal of approvals should be conditional on the ability of the operator of the TMF to prepare tailings that do not result in highly contaminated porewater.
• Procedures for mitigating all potential unacceptable impacts should be identified before deposition begins.
• New Canadian Water Quality Guidelines with lower arsenic levels have recently been introduced. Modelling should acknowledge the adoption of these more stringent levels. For the purposes of Fox Lake contamination, these levels should be treated as requirements, not merely as targets that may or may not be achieved.

The panel should be aware that the CWQG for arsenic has recently been revised to 0.005 mg/L (10 times lower than the SSWQO).

B. Fallis, Department of Fisheries and Oceans, Transcript of Supplementary Public Hearings for Midwest and Cigar Lake, La Ronge, Saskatchewan, August 27, 1997, p. 87.

• Fox Lake should not be considered to be a mixing zone. The discharge from the pit should meet the more stringent of the SSWQO and CWQG, as it enters the lake. Use of the concentrations of contaminants that would be present upon complete dilution in the entire lake allows for the existence of small localized zones of highly polluted water that could endanger the health of wildlife and humans.
• The sediments in the bottom of Fox Lake should be monitored periodically to assess their condition and the need for any possible mitigative measures. Sediment monitoring methodologies were discussed in a previous panel report. [D.G. Lee, J. Archibald and R. Neal, McArthur River Uranium Mine Project, Minister of Public Works and Government Services, February, 1997, p. 35.]
• Control of contaminants during deposition will require the use of a well-functioning underdrain. However, one rock fall has already occurred in the area where the construction of the portal to this drain is proposed. A detailed geotechnical assessment should, therefore, be undertaken to ensure that the drain can be properly constructed and that it will function adequately for as long as it is required. This geotechnical review should utilize the most current geologic mapping, rock mass characterization and rock physical property data in its assessment of portal and underdrain stability conditions.
• The tailings, when consolidated, should not be above the top of the sandstone formation.
• The migration of contaminants in the ground water should be carefully monitored and mitigation procedures deployed if necessary. Establishment of a hydraulic cage should be used as the initial mitigative procedure if contaminant migration exceeds acceptable levels; raising the water level in Fox Lake could be considered as a secondary mitigative procedure. Both of these procedures should be defined in greater detail and subjected to the scrutiny of SERM, AECB, DFO and Environment Canada before deposition begins.
• The regulators should make a careful assessment of Cogema's ability to manage the potentially dangerous JEB tailings management facility. The current management of this company appears to be chaotic. News releases have reported numerous resignations and changes at the senior management level; Uranerz, one of the partners in the JEB mill, has been openly critical of Cogema's competence; [Correspondence to Alain Marvy, President, Cogema Resources Inc., from Dr. Hikmet Akin, President and Chief Executive Officer, Uranerz Exploration and Mining Limited, June 4, 1997.] most of Cogema's technical assessment has been done by consultants, some of whom fly in only to make a presentation and then depart without contributing to or learning from other presentations; [For example, Dr. Langmuir left the public hearings almost immediately after his presentation on August 26, 1997, and was not present to hear the contradictory information presented by Richard Swider on August 28, 1997.] and the chairman of Cogema Resources Inc. admitted that the company did not have the scientific staff required to critically assess the advice given to it by consultants. [M. Poissonnet, Transcript of Supplementary Public Hearings for Midwest and Cigar Lake, La Ronge, Saskatchewan, August 26, 1997, p. 110.] A company that proposes to operate a waste dump, among the potentially most dangerous in Canada, should have greater competence and stability than Cogema has demonstrated. Before a licence to operate the JEB TMF is given to Cogema, the public and the regulators must be confident that the company has sufficient managerial and scientific strength and integrity within Saskatchewan to provide assurance that environmental damage would not result from incompetent operation of the facility.
• At times during the review, we observed that Cogema had a dismissive attitude toward the regulators and their concerns. They did not always appear to take seriously the issues raised by SERM and the AECB.

Neither the federal nor the provincial government should permit a company displaying such an attitude to be in charge of constructing and operating a radioactive waste disposal facility. Without a major attitudinal adjustment on the part of Cogema, there is a risk to the environment that supersedes the ability of scientists and engineers to design and construct a safe facility. Before approval is given, Cogema should be required to give more than superficial attention to the concerns of the regulators. It is, after all, the regulators who have been charged with the responsibility, on behalf of the people of Canada, to ensure that this facility would, if approved, be properly constructed and operated.

While fulfilling their responsibilities as regulators, AECB and SERM should be strongly supported by the federal and provincial governments and should not be subjected to undue pressure from conflicting government interests.

The panel is aware that an adequate response to many of these concerns will take considerable time. To reassure the public that this facility can be operated properly may therefore mean a substantial delay in the licensing process. Such a delay is the price the proponent must pay for the failure to provide convincing evidence that the facility can be operated safely and without adverse impacts on the environment. The regulators should not allow the fiscal consequences of such a delay to compromise their responsibility to ensure that the facility is properly designed and that there is a high probability it can be operated in such a way that the environment will be protected now and in the future.

7.3 Conclusions and Recommendations

The proposed JEB TMF, constructed using natural surround technology, provides an opportunity to realize several potential environmental benefits. Among these are the ability to use subaqueous deposition, to store tailings from several mines in one site, to avoid the use of engineered barriers, to minimize weathering problems that are likely to compromise above ground facilities, and to protect the contents of the pit from scarification by glaciers during the next ice age. Because of these potential advantages, the concept for tailings disposal represented by the JEB TMF proposal is recommended. However, there are also a large number of site-specific concerns associated with this particular site. The closeness of the JEB pit to Fox Lake, the failure of the proponent to provide convincing evidence that the lake will not become contaminated over time, and a lack of confidence in Cogema's ability to manage this facility must be taken into consideration. Consequently, it is necessary to attach several critical conditions to this recommendation. In summary, these conditions are:

• the proponent must demonstrate experimentally that porewater contaminant concentrations can be maintained at acceptable levels in aged tailings;
• if approval is eventually given, the chemical and physical properties of the deposited tailings must receive careful monitoring and the porewater quality must be periodically assessed;
• Fox Lake should not be used as a mixing zone;
• sediments in Fox Lake should be monitored;
• the more stringent of the SSWQO or the recently amended CWQG should be used when modelling the expected contamination of Fox Lake;
• a better geotechnical assessment of the underdrain portal should be provided, and design improvements made if required;
• tailings, after consolidation, should not be above the top of the sandstone formation;
• procedures for mitigating all potential unacceptable impacts should be identified before deposition begins. The construction of a hydraulic cage or raising the water level in Fox Lake should be more completely described and approved in principle by appropriate federal and provincial departments before deposition begins;
• Cogema should be required to demonstrate that it possesses adequate managerial and scientific competence before approval is given to construct and operate this highly dangerous facility;
• Cogema should demonstrate that it is capable of, and intent upon, giving thoughtful, sincere and professional attention to the concerns of the regulators, SERM and AECB; and
• arrangements should be made to provide for perpetual monitoring of this tailings management facility, if approval is given.

We are also recommending that appropriate government agencies carefully examine the internal contracts and legal arrangements governing the joint operation of the mill and tailings management facility to ensure that the arrangements are workable and sufficiently binding before giving approval to the Cigar Lake Project.

Mine workers, particularly those in underground developments, may be exposed to dangerous working conditions. The work environment at Cigar Lake presents conventional mining hazards as well as risks due to the high radioactivity of the ore being mined. It is essential that safety measures to address all potential risks be identified, and that a monitoring regime be instituted to ensure implementation of all regulations.

8.1 Jurisdictional Ambiguity and Regulatory Overlap

The administration of occupational health and safety in uranium mines comes under federal jurisdiction by virtue of provisions in the Atomic Energy Control Act. The enabling legislation for radiological protection is the Uranium and Thorium Mining Regulations (1988), soon to be revised under the recently passed Nuclear Safety and Control Act. This legislation is implemented by the Atomic Energy Control Board (AECB). Conventional occupational health and safety is governed by the Canada Labour Code, and its regulations under Part II of the Code. The responsibility for its implementation lies with the Labour component of Human Resources Development Canada (HRDC).

Radiological protection is monitored by both federal and provincial regulators, whereas conventional worker health and safety is monitored only by Saskatchewan Labour. The provincial government acquires its authority through requirements attached to the surface lease agreements made with the uranium mines. Specifically, the Saskatchewan Occupational Health and Safety Act, 1993, and The Radiation Health and Safety Act, 1985, and their attendant regulations, are the legislative instruments applied at the uranium mines. [Government of Saskatchewan, Submission to Cigar Lake Public Hearings, Regina, Saskatchewan, September, 1996, pp.19-21.]

The mining industry has voiced concern about excessive mine site inspection and licensing protocols by the various regulatory agencies, finding the current regimes in all areas, including health and safety, to be inefficient, costly and duplicative.

The duplication of regular monthly or bimonthly inspections of uranium mines is inefficient and costly from both the public or taxpayer and industry points of view. The industry recognizes the need for a competent regulatory authority and the public demands assurance that the industry is conducting its business in a safe and environmentally responsible manner. Both the industry and the public could best be served by a single competent regulator.

S. Frost, Regulation of Uranium Mining - An Industry Viewpoint, Presentation to Cigar Lake Public Hearings, Saskatoon, Saskatchewan, September 9, 1996, p. 3.

Extreme regulation, although burdensome to the productive and cost-effective operation of the mines and regulatory agencies, represents one means by which the public and the employees may be given assurance about their safety concerns. Vigilant regulation of the uranium mining industry minimizes the chance that unsafe operating practices would go unnoticed; however, it would be preferable if comparable results could be achieved by some restructuring of the regulatory process to reduce overlap and duplication of effort by federal and provincial regulators.

We wish to reiterate a recommendation made in our report on the McArthur River Project. The provincial Mines and Radiation Safety Branch is the government body most active in providing conventional health and safety inspections at uranium mines. It should therefore be provided with the authority for initiating prosecution and for enforcing compliance of conventional health and safety regulations at uranium mine sites within this province. In May, 1996, an amendment to the Canada Labour Code was enacted to permit provincial administration of nuclear projects, such as uranium mines. The federal and provincial governments have engaged in negotiations, such as the 1994 Efficiency of the Federation Initiative, with one goal being the transfer of administration of conventional workplace health and safety regulation from the federal government to the province. Although the intent to transfer regulatory control existed at the time of the Cigar Lake public hearings, the province still did not have the authority to act as sole enforcement agent of conventional health and safety at uranium mine sites. This matter should be resolved quickly.

There have been no similar negotiations concerning a possible transfer of radiological health and safety administration to the province, with the regulatory control remaining under federal jurisdiction. [Government of Saskatchewan, Opening Presentation to the Cigar Lake Public Hearings, Regina, Saskatchewan, September 4, 1996, p. 17 and pp. 34-45.] Both levels of government assume responsibilities for monitoring radiation risks to workers at uranium mine sites. Again, we wish to reiterate a previous panel recommendation, that a formal arrangement be established between the AECB and provincial regulators to share information and work-site observations on radiation monitoring, with the objectives being to strengthen worker protection, and reduce duplication in testing and reporting activities.

8.2 Conventional Safety Concerns

For the period 1991-1995, CLMC recorded no worker lost-time accidents at its test mine. [The Cigar Lake Project Environmental Impact Statement, Main Document, July, 1995, p. 6-2.] This is not atypical. As noted by Saskatchewan Environment and Resource Management, mine sites are more rigorously controlled than many other industrial work places within the province.

No other industry in Saskatchewan receives as much attention as the mining industry when it comes to health and safety. The ratio of mines inspectors to mine workplaces is considerably higher than the corresponding ratio of occupational health officers to non-mine workplaces. [Government of Saskatchewan (SERM), Submission to the Cigar Lake Public Hearings, Regina, Saskatchewan, September 4, 1996, pp. 30-31.]

There is significant arsenic and nickel mineralization within the Cigar Lake ore body, but not within the surrounding host rock. Because freeze and production drift development would be done in the host rock, workers would not be at risk from the arsenic and nickel mineralization.

During ore recovery, the use of the non-entry mining methods described in Chapter 5 would protect workers from contact with the toxic heavy metals contained in the ore. With the use of jet boring to cut the ore, all materials would be recovered in slurry form, thereby decreasing the likelihood of worker exposure to dust containing toxic contaminants. However, in instances where dry drilling (boxhole boring) would be used to recover ore, greater precautions against airborne contaminants would be required. This added protection would be obtained from the implementation of an exhaust ventilation system, similar to the one described in the EIS. [The Cigar Lake Project Environmental Impact Statement, Main Document, Cigar Lake Mining Corporation, July, 1995, pp. 3-46 to 3-50.] It will be the responsibility of the regulators to ensure that this system is functioning properly before providing the proponent with a licence to initiate ore recovery by boxhole boring.

8.3 Radiological Safety Concerns

In addition to the conventional health and safety concerns found at all mines, uranium mines carry the additional risks associated with the potential exposure of workers to radiation. These risks would be intensified at Cigar Lake, where the ore grade is very high.

Assurance of worker protection under these conditions is further compromised by continuing uncertainty with respect to the assessment of radiological risks, the selection of appropriate, conservative standards for dose limits and the length of time required to implement new standards. The AECB sets public and occupational radiation dose limits, based upon recommendations of the International Commission for Radiological Protection (ICRP). Existing federal standards, based on the 1977 ICRP-26 recommendations, are under revision, with the proposed AECB Radiation Protection Regulations calling for a considerable reduction in dose limits. The current AECB limit for workers is 50 mSv/yr and, for the public, 5 mSv/yr. The new occupational dose proposed by the AECB (based on ICRP-60 and ICRP-65) is 20 mSv/yr averaged over a defined period of 5 years, with an additional proviso that the effective dose should not exceed 50 mSv in any single year. The dose limit proposed for the public is 1 mSv/yr. Current Saskatchewan radiation dose standards are also based upon ICRP-26, although the province has amended surface lease agreements to incorporate ICRP-60 radiation protection standards, and has reached agreement with the uranium mining industry on the implementation of these standards. [E. Becker, Saskatchewan Labour, Transcript of Supplementary Public Hearings for Midwest and Cigar Lake, La Ronge, Saskatchewan, August 27, 1997, p. 49.] We urge prompt implementation of the more stringent standards; both governments should take actions to remove the existing uncertainty and confusion by expeditiously adopting the intent of ICRP-60 and ICRP-65 into regulation, and continuing to amend dose limits in line with subsequent recommendations of the International Commission of Radiological Protection.

Cigar Lake's mining methods, described in Section 5.1, have been designed specifically to prevent direct exposure of miners to the ore. Worker safety will be dependent on the proponent's ability to implement the proposed non-entry ore recovery methods and on the successful containment of the ore during transport and milling, as well as during deposition of the tailings.

Despite the protection offered by mine design, there are several areas of mine operation where special care would be necessary to avoid radiation problems. These include ventilation control, ground water containment and ore-handling during upset conditions. The proponents presented modelling studies that assessed upset conditions, such as the spill of ore slurry, and concluded that the additional exposure of workers to radioactivity would be within acceptable limits. [The Cigar Lake Project Environmental Impact Statement, Main Document, Cigar Lake Mining Corporation, July, 1995, pp. 6-12 to 6-21; Response to Request for Additional Information, March, 1996, pp. 3-5 to 3-38; Additional Information II, July, 1996, pp. 4-7 to 4 - 13; Addendum, September, 1996, pp. 11-2 to 11-5; Tailings Management Additional Information, April, 1997, pp. 9-1 to 9-5.] Although these results are somewhat reassuring, the fact that ore of this grade has not been mined previously suggests that modelling might not provide an accurate prediction of reality. Until more practical experience with ores of this grade is available, careful monitoring and unfailing vigilance by the safety officers will be required.

It was found that the maximum increase in the predicted radiation exposure due to any one of these upset conditions is 0.06 per cent of the current regulatory limit.

L. Nel, Radiation and Community Safety, Presentation of the Cigar Lake Mining Corporation, Transcript of the Cigar Lake Public Hearings, La Ronge, Saskatchewan, October 4, 1996, p. 6.

The Cigar Lake EIS predicts that the maximum exposure for any mine worker during underground mining operations would be approximately 19 per cent of the annual exposure limits in effect at the time of EIS preparation. For the average mine worker, the EIS predicts an exposure equal to 8.2 per cent of the previous allowable limit. With the introduction of the more stringent exposure limits recommended in this report, it is predicted that the maximum and average exposures for mine workers would reach 46.5 percent and 20.5 per cent, respectively, of permissible levels. During milling operations, it predicted that the workers who would receive the greatest radiation exposure would reach 11.5 mSv/yr, or 58 per cent of the new more stringent occupational exposure limits. The average exposure predicted for any McClean Lake mill worker is 6 per cent and 15 per cent, respectively, of former and amended annual exposure limits.

An exposure of approximately 50 per cent of the permitted maximum leaves little room for error and emphasizes the potential for significant worker exposure at this mine. Despite these concerns, Saskatchewan Labour has noted its agreement with the protective measures proposed:

We have thoroughly reviewed the Cigar Lake EIS, and believe that the technical challenges of mining the high grade ore at Cigar Lake can be overcome. The use of innovative mining methods, and the design of the McClean Lake Mill provide for a considerable increase in the degree of radiation control that can be exercised. [Saskatchewan Environment and Resource Management, Submission to the Cigar Lake Public Hearings, Regina, Saskatchewan, September 4, 1996, p. 39.]

However, extreme vigilance by the operator and the regulators will be required. Predicted exposures cannot be allowed to become a substitute for careful monitoring and effective mitigation measures.

8.4 The ALARA Principle

In addition to complying with regulatory limits, the proponent is required to adhere to the "as low as reasonably achievable" (ALARA) principle. It is not permissible to use a particular approach if a comparable, but safer, approach exists. Unnecessary exposure is unacceptable, even if regulatory limits are not exceeded.

Because of the highly radioactive nature of the Cigar Lake ore, extraordinary measures will be required to maintain radiological doses below regulatory limits. Developing a mine and constructing a mill that allows production to proceed without exposing workers to unacceptable doses would be a substantial engineering achievement. Once this challenge has been met, there may be a natural inclination to decrease vigilance and allow the project to operate without further consideration of additional safety innovations. It is at this point that the ALARA principle must be applied by both the operators and the regulators. All concerned must continue to seek ways to improve worker protection even if regulatory limits are being met. It is not morally, or legally, acceptable to use a particular procedure if a comparable one that will offer greater worker protection is available.

ALARA is an important concept and it is essential that it be complied with as scrupulously as any of the regulations.

8.5 Conclusions and Recommendations

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.

The proponents have attempted to assess worker radiological risks and have planned appropriate monitoring and mitigation measures to control source releases. However, it cannot be overlooked that uranium ore of such high grade has not previously been mined in an underground operation. Very careful monitoring and vigilant regulation will be required to ensure adequate protection for the Cigar Lake mine and McClean Lake mill workers.

It is recommended that both federal and provincial governments move expeditiously to adopt the intent of ICRP-60 and ICRP-65 into regulations. In addition, the proponent must also observe the ALARA principle in all phases of the Cigar Lake project as scrupulously as its legislated and regulated standards.

Jurisdictional overlap and ambiguities between the federal and provincial governments have the potential to decrease the level of worker protection as well as to introduce certain inefficiencies into the system. Because the province plays the preeminent role in performing workplace inspections and monitoring, it is recommended that Saskatchewan be given the legislated authority and responsibility for conventional health and safety at uranium mines. For radiological health protection, it is recommended that a formal arrangement be established between the AECB and the provincial regulators to share information and site inspection observations, with the objectives of strengthening worker protection and reducing duplication.

Northerners are adamant that activities such as mining not interfere with their sustainable use of the land. It is, therefore, important to assess the impacts of mining on the local as well as the regional environment, looking both at the effects observed during the operational phase of the mine as well as any residual effects after decommissioning.

...if we do not use the land properly, we do not have a future.

G. Ross, Mayor of Pinehouse, Transcript of Cigar Lake and McArthur River Public Hearings, Pinehouse, Saskatchewan, October 7, 1996, p. 129.

The Cigar Lake mine would impact the environment in many ways. First, from the mine itself would come minewater discharge and aerial emissions of dust and gases. Secondly, the disposal of mine waste rock, with its potential to be acid-generating, would have an impact on the surrounding environment. Thirdly, milling at the McClean Lake mill and deposition of tailings in the JEB TMF would contribute to the impacts at the McClean Lake site.

The effects of mill effluent are not considered independently in this report; the reader is referred to a discussion on the monitoring of mill and minewater effluent from the McClean Lake mine in our earlier 1993 report, [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, Section 5.3.] and some additional comments in our 1997 report on the Midwest mine. [D.G. Lee, J.F. Archibald, and R. Neal, Midwest Uranium Mine Project, Supply and Services Canada, 1997, Section 10.1.] As well, these effects are included in an assessment of the cumulative effects of the Cigar Lake mine and the other uranium mines in the eastern region of the Athabasca Basin (see Section 9.4).

9.1 Monitoring of Aerial Emissions and Minewater Discharge

Predictions presented in the EIS indicate that the atmospheric emissions from the mine and ore preparation facility, and the discharge of treated minewater effluent would have little impact on the environment surrounding Cigar Lake. This is so because of the way in which the mine has been designed, and the fact that the ore will be milled, and the tailings disposed of, at McClean Lake.

9.1.1 Aerial Emissions

The Cigar Lake Mining Corporation predicts that aerial emissions would be low and would likely have very minor impacts. [The Cigar Lake Project Environmental Impact Statement, Main Document, Cigar Lake Mining Corporation, July, 1995, Section 5.3.1.] We agree with this assessment. The emissions from the mine ventilation system and the ore preparation facility are predicted to increase the radon concentration by an average of approximately 1 Bq/m³ within a 2 km radius of the mine, compared to an average background concentration of 6 Bq/m³. These emissions would be low compared to those of most other uranium mines because the use of ground freezing at Cigar Lake would limit the movement of radon into the mine. In addition, the ore stream would be contained, from extraction to transportation. For similar reasons, the predictions for emissions of other long-lived radioactive dusts are also low.

The concentrations of total suspended particulates (TSP) from the mining operation are predicted to be very low because of the wet process proposed for ore preparation. The predominant source of TSP would be road dust which is not radioactive and is largely chemically inert.

Finally, the production of oxides of sulphur and nitrogen from the exhaust gases of mine and surface equipment would be low because much of the equipment is electrically operated.

The proposed monitoring program for air, soil, and vegetation (lichens, blueberries, alder, and willow) is adequate and the locations of the various sampling stations are appropriate. However, the monitoring program should be extended to include a terrestrial vertebrate to ensure that transfers along the food chain, as predicted by pathways analysis (see Section 9.4), can be assessed.

9.1.2 Impacts of Minewater Discharge

The proposed use of freezing and grouting would significantly reduce the amount of water entering the mine, and some of the water that does enter the mine would be used in the preparation of the ore slurry. The volume of treated minewater effluent, predicted to average approximately 684 m³/day, [The Cigar Lake Project Environmental Impact Statement, Additional Information, Cigar Lake Mining Corporation, March, 1996, p. 1-52.] is consequently much lower than at any of the present Saskatchewan uranium mines.

The treated effluent would also be considerably lower in dissolved salts and other contaminants compared to the effluent released from milling operations. It would be released into a muskeg which first drains into Aline Lake and, eventually, into Waterbury Lake. Based on hydrological measurements during test mining between 1986 and 1992, there would be a ninefold dilution, at least, of the effluent at the exit of Aline Lake. The water would then drain along Aline Creek for about 1500 m before exiting into Seru Bay of Waterbury Lake. It is predicted that the concentrations of key contaminants in Aline Lake would only reach 10 to 50 per cent of the Saskatchewan Surface Water Quality Objectives, even with a worst-case assumption showing no contaminants removed in the muskeg area. [The Cigar Lake Project Environmental Impact Statement, Additional Information, Cigar Lake Mining Corporation, March, 1996, Section 1.3.2.]

Waterbury Lake supports a productive sports fishing operation that is an important resource to protect. However, it appears that the risk to fish and other aquatic organisms is acceptable, given the low volume of effluent to be released.

In general, the aquatic monitoring program proposed to assess the impacts of treated minewater discharge is acceptable. There remains a need to identify appropriate control sites where no mine-related impacts are predicted. In particular, a small lake to match Aline Lake should be identified. In addition, the method of sampling sediments could be improved (see Section 9.4).

9.2 Monitoring of Waste Rock

As described in Chapter 6, mining would produce 2.6 million tonnes of potentially acid-generating waste rock that would require appropriate disposal. There would appear to be at least two viable disposal sites: the mined-out Sue C pit at McClean Lake; and Lake 497, located on the Thin River drainage system approximately 6 km west of Cigar Lake. The monitoring requirements for these two options would obviously be very different.

In some respects, monitoring for the Sue C pit option would be similar to the monitoring required for tailings management facilities. There would be a need to monitor and understand the movement of groundwater through and around the pit, to measure the solubility of contaminants in the waste rock under the conditions in the pit, and to monitor the spread of contaminants from the pit via the groundwater into nearby surface waters. In addition, if the remainder of the Sue C pit above the waste rock were allowed to fill with water, the levels of contaminants in the pit water would also require monitoring.

Monitoring for the Lake 497 option would require a standard monitoring program for the surface waters impacted by mining activities, similar to that which the proponent has described for assessing the impacts of minewater discharge. Thus, water chemistry, the rate of water flow, sediment chemistry, aquatic macrophytes, benthic invertebrates, and fish would require monitoring in Lake 497 and at one or more points downstream. In addition, a suitable control lake should be identified as a reference point.

It would be the responsibility of the regulatory agencies to enforce an appropriate monitoring program for whichever site is selected for the disposal of waste rock. The main outstanding issue is how long monitoring should continue in the postdecommissioning period. If the waste rock is placed in Lake 497, there will be a need to check periodically to see if the rock is covered with sufficient water to prevent oxidation and the production of acid. The water chemistry of the lake should also be measured during these checks. This form of monitoring should continue indefinitely because the potential for this type of rock to produce acid does not decrease with time. If deposition is in the Sue C pit, long-term monitoring for contaminants in the groundwater downstream from the pit would also be required. For either option selected, mitigation possibilities for the most likely causes of unfavourable environmental impacts should be identified in advance.

9.3 Monitoring of the JEB Tailings Management Facility

As described in Section 7.2, the proposed method for disposal of tailings from the McClean Lake mill would involve placing them in the JEB pit, where it is predicted they would consolidate until their permeability becomes much less than that of the surrounding rock. If this were to occur, ground water would flow preferentially around the tailings decreasing the risk of contamination to surrounding surface waters.

However, evidence was presented which suggests that the source terms used in arriving at these predictions may not have been conservative. [R. Swider, The Cigar Lake and Midwest Projects Tailings Disposal, Richard C. Swider Consulting Engineers Limited, Toronto, Ontario, August 21, 1997.]

This concept, therefore, needs to be confirmed by detailed field observations during the operating, decommissioning and postdecommissioning phases, if this facility is approved. These observations are prescribed by the licensing procedure. Thus, the construction licence for the JEB Tailings Management Facility required the operator to measure the characteristics, including the permeability, of the overburden and various layers of rock forming the pit wall. Similarly, the operating licence would prescribe how the tailings, the groundwater, the water in the pond overlying the tailings, and the water collected in the drainage sump beneath the tailings would be monitored. Subsequently, the licence for the decommissioning phase would require the monitoring of the final consolidation of the tailings, the settlement of the cover, and restoration of the groundwater. The proposed monitoring program for the various phases has been described by the proponent [The Cigar Lake Project Environmental Impact Statement, Addendum, Cigar Lake Mining Corporation, September, 1996, Section 3.7 and Section 8.] and it would be the responsibility of the regulatory agencies to enforce an appropriate monitoring program for the facility.

If the tailings management facility is approved, one outstanding issue to be addressed is how long it should be monitored after the pumps are shut off and the water table restored. Local people deserve to know that contaminants are being contained within the facility and to be assured that, in the long term, any unacceptable leakage of contaminants would be mitigated before organisms were harmed. Since modelling predicts that it would take about 8000 to 9000 years for the maximum concentration of contaminants to reach the nearest water body, Fox Lake, [The Cigar Lake Project Environmental Impact Statement, Tailings Management -- Additional Information, Cigar Lake Mining Corporation, April, 1997, Section 11.3.] it would be necessary to continue monitoring at some level for the foreseeable future. The panel believes, therefore, that the only way in which the people of the region can be assured of environmental protection is to monitor the facility indefinitely; it is not possible to guarantee a walk-away, zero-risk storage facility. The details of the monitoring program, possible maintenance of the facility, and ability to respond to any contingencies will require careful thought and appropriate funding.

If properly constructed, tailings management facilities should not require expensive maintenance and there should be little likelihood of incurring large costs for mitigating future problems. Nevertheless, it is apparent that the environmental risks associated with uranium tailings disposal facilities will require periodic monitoring for as long as can be foreseen. The idea that it might be possible in a few years to walk away from a site that contains millions of tonnes of material that is both toxic and radioactive is not realistic. Instead, provisions should be made for continuous monitoring of all of the existing Saskatchewan tailings disposal areas, as well as the underground excavations that will eventually be filled. The word "decommissioned", when used in connection with uranium tailings management facilities, means that the site should be left in a condition that will require only infrequent monitoring and minimal maintenance; it does not mean that the site can be abandoned and forgotten about.

Decommissioning costs would be covered by financial guarantees from the mining companies as legislated by the federal and provincial governments. However, postdecommissioning costs for the perpetual maintenance and monitoring of tailings management facilities, as well as costs of any contingencies which might arise, should be derived from a dedicated permanent fund controlled by an authority appointed to oversee these activities. The fund might be called the Uranium Mining Contingency Fund (see Section 10.4).

9.4 Pathways Modelling and Cumulative Effects

The proponent has used pathways analysis to predict the movement of contaminants in the environment and the dose to biota and human receptors at different locations. By necessity, the models used in these analyses are complex because they integrate contaminant inputs from a variety of sources, and follow their movement along different pathways to human receptors. The purpose of this type of modelling is to assess the magnitude of risk to humans, not to produce exact predictions. The latter is not possible because contaminant concentrations vary in both time and space, and because animals of any one species do not all have identical diets, resulting in a transfer of contaminants that is not constant.

Modelling reported in the EIS predicts that semi-aquatic animals, such as moose, beaver and scaup, would receive the highest radiation doses because they receive both aquatic and atmospheric impacts. [The Cigar Lake Project Environmental Impact Statement, Supporting Document No. 2, Cigar Lake Mining Corporation, July, 1995, Section 6.7.] Even so, the highest predicted dose, 32 µGy/hour (to a scaup residing on Aline Creek), is still less than the 1 per cent Response Threshold for the most sensitive life stages of a mammal (125 µGy/hour). The average dose for most organisms was 1.25 µGy/hour or less. It was concluded that there would be no harmful radiological effects to animals at the Cigar Lake site.

The proponent used pathways analysis to estimate the radiological dose to humans living close to the mine site both during operations and after decommissioning. [The Cigar Lake Project Environmental Impact Statement, Supporting Document No. 2, Cigar Lake Mining Corporation, July, 1995, Sections 6.8 and 7.3.] During the operational period, Jackson's Lodge on Waterbury Lake, located about 5 km east of the mine, was chosen as a suitable location for a hypothetical human population. It was assumed that persons lived at the lodge for four months during the summer (similar to the current pattern of use) and obtained all of their food and water from the immediate area during their period of residence. The model predicted a peak exposure of 0.108 mSv/yr, which occurred towards the end of the operational period. This compares favourably to the current ICRP guideline of 1 mSv/yr.

For the period after decommissioning, the hypothetical human population was assumed to live in the permanent residence at the mine throughout the year and subsist entirely on local country foods and local water. The residence would be located approximately 3.5 km northeast of the mine site. In this case, the model predicted peak exposure rates immediately after closure with dose rates at least 100 times less than the value reported for the Jackson Lodge population.

The cumulative effects of all the mines in the eastern part of the Athabasca Basin were assessed for residents of Wollaston Lake, Hatchet Lake and Black Lake. The estimated doses were well below regulatory limits and approximately 1 per cent or less of the natural background dose. The Atomic Energy Control Board made an independent modelling assessment of dose estimates and obtained comparable values. [L. Chamney, Atomic Energy Control Board, Regulatory Review of the Radiological Impact of Cigar Lake and McArthur River Uranium Projects, Submission to the McArthur River and Cigar Lake Public Hearings, Saskatoon, Saskatchewan, September 16, 1996.]

9.5 Conclusions and Recommendations

On the basis of available evidence, it can be concluded that the potential radiological impact of the Cigar Lake mine on the biota and humans, now and in the future, would be acceptably low.

Monitoring will be required over a much longer time span than suggested in the Environmental Impact Statement. The JEB Tailings Management Facility, if it is approved, and the mine waste rock site, when it has been selected, will require perpetual monitoring.

10.1 The Cigar Lake Mine Site

The intent of decommissioning activities is to dismantle mine infrastructure and make the sites safe. The objective of reclamation activities is to return a site to a productivity level equal to or better than that which existed before mining activities.

The mining regulations administered by both federal and provincial governments require that a site-specific conceptual decommissioning plan be submitted, reviewed and approved prior to the issuance of an approval to operate a mine. Mining companies are encouraged to conduct decommissioning and reclamation activities as soon as possible after an area is removed from production. This allows the conceptual decommissioning plan and the associated financial surety to be updated continually to reflect existing conditions.

At the end of mining, the operator must submit, for review and approval, a detailed final decommissioning plan based on existing mine conditions and the best technology available at the time. Once decommissioning and reclamation work have been completed, the site must be monitored for a number of years, the length of time being dictated by the stability of the site and the levels of any contaminants being discharged into the receiving environment. After monitoring has confirmed that decommissioning has been successful, the proponent is released from further obligations and the Province accepts responsibility for the site.

At the Cigar Lake mine site, the majority of the underground openings would be backfilled with waste or cement as mining progressed. At the conclusion of mining, all salvageable materials would be removed from the mine, the remaining underground openings would be utilized for the final disposal of contaminated surface materials and the mine shafts would be sealed. Decommissioning, as proposed in the EIS, would include removal of all surface facilities and infrastructure with the possible exception of the permanent camp, the airstrip and the access road to Provincial Road 905. Based on discussions with northern communities at the time of decommissioning, the camp, the airstrip and the access road might be sold to interested parties to develop some type of commercial venture or community facility.

Reclamation, conducted on all areas that had been subject to surface disturbance, would include a gamma scan to ensure that radioactivity had returned to original background levels. The land would then be appropriately contoured and revegetated.

Certain features of the Cigar Lake proposal suggest that decommissioning of the mine site to a near "zero footprint" legacy should be possible: the milling of the ore would be at a location remote from the mine site; some of the waste would be placed in mined-out drifts underground; and custom-designed waste rock management strategies have been proposed. Therefore, no significant environmental concern should remain at the site after decommissioning and reclamation. All activities during operation should be planned and implemented in a manner that supports the overall objective of reducing or eliminating the size and duration of the footprint of mining at the Cigar Lake site.

During public hearings, northern residents indicated a desire for consultation on the conceptual and final decommissioning plans. It is important that local people be involved because it is they who must live with the decommissioned site in their backyard. Their involvement should include input into the proposed decommissioning plans and active participation in reclamation and postdecommissioning monitoring activities. The Environmental Quality Committees, now established in northern Saskatchewan, provide an ideal vehicle through which local people can be consulted on decommissioning issues, activities and monitoring.

10.2 The JEB Tailings Management Facility

If the JEB TMF is approved for disposal of mill tailings, the proponents propose to decommission it by covering the tailings with a cap consisting of about 20 m of sand, waste rock and till. [The Midwest Project Environmental Impact Statement, Tailings Management - Additional Information, Cogema Resources Inc., April, 1997, pp. 13-1 to 13-6.] The purposes of the cap would be to prevent plants, animals, birds and people from accidentally coming in direct contact with tailings, and to drain groundwater away from the pit.

Once the tailings reach a predetermined level, they would be covered by two metres of sand. The water cover would then be reduced to about 1 m and, during the following winter, 2 m of clean waste rock would be placed on the ice. When the ice melts during the subsequent summer, a leachate collection system would be installed to dewater the sand layer.

Temperature and pressure transducers would be installed in the tailings and, when instrumentation has indicated that all of the ice has melted, the remainder of the pit would be filled with sufficient waste rock to create a mound over the pit. It is anticipated that the weight of this mound would cause approximately 14 m of settling due to consolidation of the tailings. This consolidation process would expel porewater into the sand layer where it would be recovered by the leachate collection system and sent to the water treatment plant.

During the consolidation stage, occasional recontouring of the mound would be necessary to maintain a well-drained surface. When consolidation is complete, a final cover of till would be placed to bring the top of the mound above the artesian water level in that area. The mound would then be graded and revegetated.

Do you have some examples of other mine sites that have used the solid cap and was it effective?

G. Ross, Mayor of Pinehouse, Transcript of Supplementary Public Hearings for Midwest and Cigar Lake, La Ronge, Saskatchewan, August 26, 1997, p. 153.

During hearings, members of the public questioned the ability of Cogema to place waste rock on top of a pit filled with semi-solid tailings. In particular, it was suggested that, over time, the rock cover might sink into the pit and the tailings, instead of consolidating, might ooze up over the edges of the pit. When asked directly for examples of other places where this approach had been successfully applied, the company's reply was evasive.

In our opinion, the method proposed for decommissioning the JEB TMF is conceptually acceptable. Theoretical indications are that capping of the pit in the manner proposed would provide for the greatest environmental security in the long term. However, experimental verification of the effectiveness of the proposed approach should be sought before deposition begins. Experiments designed to test the response of aged paste tailings to pressure should, therefore, be undertaken. If the application of pressure causes them to flow rather than to consolidate, a more acceptable method for decommissioning the pit should be developed. Unless experimental evidence indicates that it can be successfully decommissioned, the JEB pit should not be licensed as a tailings management facility.

10.3 Financial Guarantees

Both the federal and provincial governments have introduced legislation and/or regulations requiring mining companies to provide financial guarantees, prior to mine start-up, that will be available to cover the full cost of all decommissioning activities. The financial guarantee is intended to ensure that uranium mine and mill sites can and will be decommissioned at no cost to tax payers. The amount of the financial guarantee required by government is based on the requirements outlined in the conceptual decommissioning plan. The plan is subject to regular review to ensure that it reflects existing site conditions.

10.4 Uranium Mining Contingency Fund

The financial guarantees outlined in Section 10.3 would cover monitoring and mitigation costs for, at most, a few decades after mining ceases. However, tailings areas have the potential to pose a threat to the receiving environment for centuries. Uranium mill tailings, in particular, require that containment facilities function efficiently for a very long time.

Decommissioned tailings management facilities would be required to contain contaminants for millennia, during which time many aspects of both the bio-physical and institutional environments will change. Some mechanism must be established to provide for regular investigation of the integrity of contaminant containment and the performance of mitigative measures, should they be required, in the period after institutional responsibility for the area has been transferred from the mining company back to the Province.

For this reason, the panel's report on the McArthur River Project [D.G. Lee, J.F. Archibald, and R. Neal, McArthur River Uranium Mine Project, Supply and Services Canada, 1997, p. 48.] recommended that a fund be established to provide for monitoring and any mitigation required after the responsibility for the sites is returned to Province. The Province of Saskatchewan, in its response 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 Mining Developments in Northern Saskatchewan, McArthur River Project, Government of Saskatchewan, May 1997, p. 21.]

It is recommended that Saskatchewan move as expeditiously as possible to implement this recommendation.

The value of the contingency fund should be sufficiently large to cover the full costs of the long-term monitoring and maintenance of tailings management facilities and the potential implementation of mitigative measures. Rather than establishing such a fund for each mine independently, there may be merit in considering the establishment of an industry-wide fund which could be called the Uranium Mining Contingency Fund. Such a fund could provide better overall fiscal protection to future generations and cost less to establish than individual funds for each site. There should also be a single authority to oversee the management of the fund and the maintenance, monitoring and mitigation activities, at all decommissioned uranium mine sites in Saskatchewan.

10.5 Conclusions and Recommendations

Decommissioning, since it will take place in the future, is only described conceptually at this stage; the scrutiny and acceptance of specific details must be entrusted to the regulatory agencies. These agencies should ensure that they receive advice from local residents at each stage, and for all elements, of the decommissioning process. Because of the proximity of the mine site to northern communities, this involvement should extend beyond consultation, to participation in the decommissioning, reclamation and postdecommissioning monitoring activities. The Environmental Quality Committees are appropriate vehicles through which northern community residents could be consulted on decommissioning issues, activities and monitoring.

This project, and in particular the JEB Tailings Management Facility, if it is approved, would require long-term monitoring and possible mitigative activities in the future. Arrangements should be made to guarantee that monitoring and any required mitigation could occur without placing a financial burden on future generations. For this reason, the panel reiterates its recommendation for the establishment of a contingency fund to provide for the ongoing costs of long-term monitoring and mitigation, after the responsibility for the sites is returned to the Province.

The proponent proposes to transport Cigar Lake ore from the mine to the McClean Lake site for milling, a distance of about 80 km. A haul road approximately 50 km in length would be constructed to connect the Cigar Lake mine site with Provincial Road 905, just south of Points North Landing. The ore would be transported for the remaining distance along Road 905 and, finally, along the private McClean Lake property access road. It would be shipped as an ore slurry enclosed in specially designed vessels, loaded four at a time, on large trucks designed in a B-train configuration.

In spite of the strictest precautions, and for a variety of reasons, road accidents may occur. The possibility of ore spills during transport, in particular at stream crossings, is of great concern to the public. The mitigation procedures and appropriate compensation arrangements in the event of environmental damage should be identified before the shipping of ore along this route is permitted.

11.1 Ore Transport Vessels

The design of the vessels to be used for ore transportation under northern conditions is of paramount importance. It is essential that the vessels not release radioactive material in the event of an accident while travelling from the mine to the mill. The design of the vessels must also consider difficulties which might arise during the unloading of the ore slurry. Unforeseen situations, such as blockages due to freezing or segregation of the ore while stored in the vessels, are likely to arise. The vessels should be designed to ensure such occurrences would not require manual mitigation, which could expose workers to high levels of radiation.

During its licensing process, the AECB will address the safe packaging and transport of the Cigar Lake ore. The regulations administered by the AECB require that the packaging standards for radioactive material match the hazards posed by the material being transported. The hearings were informed that existing standards for the packaging of high grade uranium ore are being upgraded and that these new standards would be incorporated into the licensing conditions for the packaging of Cigar Lake ore. As uncertainty may be created by any changes in the standards, the panel emphasizes the importance of public consultation by AECB during its licensing process.

11.2 Transportation Routes

11.2.1 Cigar Lake Access Road

Most of the route proposed for the Cigar Lake access road follows a corridor already disturbed by the existing Cigar Lake temporary road and power transmission lines. Provincial regulators would require the proposed route to be realigned in the vicinity of water bodies where it lies within the 31-metre shoreline buffer zone or, alternatively, that a shoreline stabilization program be carried out. As the road would be used to transport radioactive ore, the utmost effort should be made to ensure the final route chosen lies outside the shoreline buffer zone.

A major issue for northerners is whether the proposed road to the Cigar Lake site would be a public or private road. Government policy requires that all access roads be public, although restricted access may be permitted for exceptional circumstances. As the proposed road to the Cigar Lake site would originate at Provincial Road 905, there is concern that unrestricted access might lead to overharvesting of the wildlife resources of the area, particularly at Waterbury Lake. However, many members of the public also desire to use the road for other purposes. This issue is currently unresolved and it is our opinion that the most appropriate use of the road will become apparent only with time and experience. In any event, it is important that the public be consulted on this issue before a decision is reached.

11.2.2 Cumulative Use of Northern Highways

In hauling its ore to the McClean Lake mill, Cigar Lake would not be the only user of Provincial Road 905. The road already carries traffic for activities related to other mining projects and for Points North Landing. If other proposed developments are approved, it may also be used for the Midwest uranium mining project and as part of the main supply route for the Athabasca Basin communities using the proposed road from Points North Landing to Black Lake. Inevitably, Road 905 will carry many other users, including Athabasca Basin residents, tourists and mine employees and suppliers. In short, heavy cumulative use of the stretch of Road 905 proposed as part of the Cigar Lake ore haul corridor is a probability. Such use will produce environmental impacts such as higher levels of noise and of traffic-generated dust. Further, much of this traffic would consist of multi-axle vehicles transporting hazardous or radioactive material, and requiring special safety considerations.

It is essential that northern roads, such as Provincial Road 905, be maintained at a safety standard appropriate to the volume and nature of traffic travelling on them. Use of Road 905 in the vicinity of the mines should be monitored to ensure that the maintenance standards and design criteria applied to the road are adequate to ensure safety for all users. The results of the monitoring should be considered in public discussions on the road improvement program.

11.2.3 Highway 102 and Provincial Road 905

The public expressed concerns over public safety on Highway 102 and Provincial Road 905, particularly with respect to the continuous deterioration in the condition of the roads. It was reported that the roads were not designed to support the size and frequency of loads currently carried on them; that road maintenance activities have not kept up with use of the roads; and that the money spent on road maintenance has decreased in spite of an increase in traffic. There is also concern over the capability of municipal emergency response services to respond appropriately to road accidents involving hazardous materials.

Northerners are also concerned that the heavy use of the roads by multi-axle vehicles could be having a negative impact on the tourism industry of the region. Poor road conditions, combined with heavy use by big trucks, would discourage travel by tourists and thereby interfere with attempts to diversify the northern economy.

A financial agreement has been implemented between the Saskatchewan Government and Cameco, Cogema and their partners for the purpose of upgrading Highway 102 and Provincial Road 905. During hearings held in the north, the public emphasized the need for northern communities to participate in discussions on the road upgrade program.

11.3 Conclusions and Recommendations

It is recommended that the public be consulted by federal and provincial authorities on several transportation-related decisions: on the development of accident contingency plans; on the licensing of transportation containers and vehicles; on decisions regarding the proposed Cigar Lake access road, particularly public access; on the highway upgrade program and on the eventual decommissioning of roads. These consultations should take the form of public meetings, organized by the provincial authorities, and be held in the northern communities impacted significantly by transportation-related activities.

It is recommended that the volume and nature of traffic using Provincial Road 905 in the vicinity of the mines be monitored periodically to determine whether the design and maintenance standards applied to the roads are adequate to ensure the safety of all travellers.

12.1 Contamination of Air, Water and the Food Web

A fundamental concern of many northerners is the possibility that uranium mining and milling operations might poison the air that they breathe, the water they drink, and the country foods they eat. This issue has been partly considered by pathways modelling and the assessment of cumulative effects discussed in Section 9.5. The conclusion from these analyses is that radiological risks are extremely low.

Even though it is anticipated that the combined effects of the uranium mines would be acceptable, it is necessary to confirm all predictions using a well-defined monitoring program. Saskatchewan Environment and Resource Management (SERM) and the Atomic Energy Control Board (AECB) agreed to establish such a program in response to an earlier recommendation of the panel. They formed the Cumulative Effects Monitoring Working Group (CEMWG) in 1994 with technical advice from representatives of Saskatchewan Health, Environment Canada, the Department of Fisheries and Oceans Canada, the Saskatchewan Research Council, The University of Saskatchewan Toxicology Centre, the Saskatchewan Northern Mines Monitoring Secretariat, and Terrestrial and Aquatic Environmental Managers Ltd. This working group continues to improve the IMPACT/AECB model, which evaluates cumulative environmental effects.

The CEMWG has also established a cumulative effects monitoring program to test the reliability of the model's predictions using field observations. A total of 63 sample stations has been established. Valued ecosystem components (VECs), which are monitored on a 3-year cycle, include air, soil, lichen, blueberry, spruce needles, caribou, spruce grouse, water, depositional sediments, macrophytes, benthos, and fish. Each VEC is measured for concentrations of radionuclides and metals, together with other physical and chemical parameters.

We endorse the CEMWG initiatives and note that the existence of this diverse and highly competent team of scientists should reassure Athabasca residents and other northerners about the safety of country foods. Attempts should, however, be made to involve northern residents more closely in this project and its results. This could be achieved if the residents participated in the collection of information and had representation on the monitoring committees. A start has already been made in this direction by a food chain study in which the CEMWG employed local hunters for the collection of caribou in the Wollaston Lake area. [P. Thomas, Radionuclide Analyses of Saskatchewan Caribou -- 1995, Final Report, October, 1995, Saskatchewan Environment and Resource Management and Saskatchewan Health.]

The objective of the Wollaston Lake caribou study was to measure radionuclide body-burdens and to assess transfers of radionuclides from lichen to caribou and, potentially, to humans. The data obtained suggested that the radiation dose from eating Wollaston-area caribou meat is similar to the dose received from eating caribou meat harvested in an area of the Northwest Territories where there is no uranium mining. We encourage government agencies to continue initiatives where local residents are involved in such monitoring programs.

The available information suggests that there has been no detectable regional contamination of the food web in northern Saskatchewan. It appears that there is no danger, at present, associated with the consumption of locally grown plants, meat, or fish. This is fortunate because locally harvested foods continue to make an important contribution to the diet of many people in northern Saskatchewan.

It is, however, important that precautions be taken to prevent the possibility of future contamination of the food web. An early warning of such contamination would be provided by continuous monitoring of the type provided by the CEMWG.

12.2 Community Involvement

A common theme running through many of the presentations from northern Saskatchewan was that developments, such as mining, should be made in partnership with northern communities. There is a perception that many of the solutions to problems associated with northern development have been imposed on the region and that northerners are not in control of their lives.

The last area that I wish could be developed is a way to get the south to quit doing things for us and start doing things with us. I am happy to hear that the Environmental Quality Committees are now in place. I can now talk to people who know who I am, where I am from, and understand what it means to us to be a northerner. I believe these groups can bring all the stakeholders together in a way that will show the rest of this province that the north has matured and that we are equal players in the building of this province.

R. Rediron, Transcript of the McArthur River and Cigar Lake Public Hearings, Saskatoon, Saskatchewan, September 11, 1996, p. 189.

A start has been made on the establishment of vehicles through which northerners can become involved in activities related to the development of uranium mining in the region. One initiative, the formation of Environmental Quality Committees, was made by the provincial government, and the other, the Athabasca Working Group, came from the uranium mining industry.

12.2.1 Environmental Quality Committees

In response to a recommendation from this panel, the Government of Saskatchewan established three regional Environmental Quality Committees (EQCs) in 1995. [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. 11.] Representatives of the South-Central and Athabasca EQCs submitted several recommendations to the panel, all of which have received consideration in the preparation of this report.

The mining companies, the various provincial government departments and the communities appear to be taking these committees seriously and attempting to actively involve them in various monitoring activities. This approach is welcome, because the effectiveness of the EQCs depends on the opportunities provided for them to work in concert with the mine operators, the government regulatory agencies and the communities which they represent.

We fully endorse these committees and commend the mining companies and government departments for their willingness to work with, and support, the EQCs. We do, however, have two specific recommendations with regard to the operation of the EQCs. The first is that adequate, continuing financial support must be provided to allow the committees to effectively address the various issues related to uranium mining in northern Saskatchewan. Future activities in which EQC involvement is desirable require that committee members have an increased understanding of the issues. If the EQCs are to fulfil their mandate effectively, it will be necessary to dedicate additional resources for relevant training and information sessions for their members. It is also important, for obvious reasons, that the EQCs do not become dependent on grants from the mining companies to support their activities.

The second recommendation is related to the need for the Atomic Energy Control Board to further develop its EQC support and participation. The AECB plays a unique role in the regulation of the uranium mining industry. It has much to offer to, and much to gain from, strong involvement in EQC activities. Its participation is essential to their continued success.

12.2.2 The Athabasca Working Group

Prompted by a desire for better communication with the people of the Athabasca region, the presidents of Cameco and Cigar Lake met with 23 community leaders and representatives from Camsell Portage, Uranium City, Fond du Lac, Stony Rapids, Black Lake and Wollaston Lake in March 1993. A discussion of their concerns identified three major issues:

• a desire for more opportunities for jobs, training and business, but not at the expense of the environment;
• a need for a written guarantee stating that companies would protect the environment and compensate for any damage that might result from mining activity; and
• a desire to receive benefits and revenues beyond those of jobs, training and business opportunities.

The participants agreed that discussions should continue until a formal written agreement is reached on these three issues. This led to the formation of the Athabasca Working Group (AWG). Cogema Resources Inc. joined the process in January, 1994, making this the primary means of communication between all of the uranium mine operators and the Athabasca residents. The AWG consists of two members from each of the six Athabasca communities, and at least one representative each from Cameco, Cigar Lake, and Cogema. This group wishes to remain free of political involvement; government officials, and officers from the Métis Society, Prince Albert Grand Council, and the Federation of Saskatchewan Indian Nations are not included, except by invitation.

The AWG has no established rules or procedures; it is simply a forum for discussing and negotiating issues between the uranium mines and the Athabasca communities. The selection of issues to be discussed is determined by the consensus of the community representatives, and any agreements reached would be formulated as legally binding documents.

The AWG has devoted about half of its discussion time to dealing with mine site issues. Community members who work at the mines address their concerns to their AWG members who in turn bring them to the table at the next AWG meeting. For example, one problem identified was the inability of many northerners to communicate fully with human resource people at the mine sites. In response to this concern, an employee relations counsellor was hired to help all northern employees with their concerns and grievances.

The remainder of the AWG discussions has focused on the three main issues identified in the first meeting. The AWG has reached agreement on the first issue, and has defined procedures to maximize jobs, training and business opportunities for the people of the Athabasca region.

We support the AWG initiative and its attempts to establish consensus between the people of the region and the mining companies on the way in which mining is carried out in the north. The lack of formal procedures is a strength when discussions are going well, but may prove to be a weakness when consensus is difficult to reach. There is also a possibility that the mining companies might feel less motivated to reach agreement on outstanding issues after mine approvals have been granted. The panel encourages the continuation of the AWG initiative, and suggests that it establish terms of reference and procedures to confirm and protect the dialogue between the communities and the mining companies.

12.3 Community Health and Vitality

Saskatchewan Health considers health to be "a dynamic process involving the harmony of physical, mental, emotional, social and spiritual well-being. Health enables individuals, families and communities to function to the best of their ability within their environment." [Government of Saskatchewan, Submission to the McArthur River and Cigar Lake Public Hearings, Regina, Saskatchewan, September 4, 1996, p. 40.] In addition, the province's wellness approach recognizes that the state of our health is affected by factors like employment, income, education, housing, the environment, and individual lifestyle choices. Thus, the health of northerners is intimately connected to community vitality. Indeed, northerners themselves see how community health and vitality are intimately connected, for good or bad, and how they may be affected by uranium mining.

Some Athabascan communities do not have fundamental water and sewer services. People are hauling water by hand, and dumping sewage out back doors. This is a health issue, a cost of living issue, and community vitality issue. As mentioned earlier how can we realistically speak about the millions of dollars in revenues that are generated in our traditional lands when the poverty of these communities is there for all to see? [Athabasca Environmental Quality Committee, Submission to the McArthur River and Cigar Lake Public Hearings, La Ronge, Saskatchewan, October 2, 1996, p. 9.]

The health and quality of life of northern residents is subject to both positive and negative impacts from uranium mining. On the positive side, enhanced employment and business opportunities in northern communities may provide a better standard of living and be a source of optimism and hope for community members. Mine employees may also be good role models, encouraging students to stay in school and others to upgrade their education. The seven-day-in, seven-day-out rotation allows wage earners to remain active in traditional pursuits and to have quality time to spend with their families. The presence of mines may bring reduced transportation costs of goods throughout the region, and often results in an improved infrastructure (roads, electrical power, water and sewer, etc.) that contributes to the health and vitality of a community.

On the negative side, there is a communal sense of injustice and anger caused by the extraction of resources worth billions of dollars from the traditional lands of communities where many are struggling to meet basic needs. The high expectations of northerners for jobs may not be realized. Tensions may develop between community members with jobs and those without, and between those who favour mine development and those who oppose it. Uranium mining might cause a deterioration in the traditional way of life that is valued by many northerners. Fear of environmental pollution could create anxiety in communities that share the same watershed as the mines. Some employees might decide to move to southern cities, thus depriving northern communities of income and potential leadership. In addition, improved infrastructure might result in concerns about traffic accidents and possible spills of toxic materials.

Although this description of possible impacts is far from exhaustive, it does indicate that uranium mining has the potential to cause both positive and negative impacts on the health and vitality of northern communities. Therefore, if uranium mining is to remain a feature of the northern economy, it is as important to monitor its impacts on community health and vitality as it is to monitor its impacts on the environment. At least as much attention should be directed toward maintaining the well-being of the people of the region as is devoted to preserving the biota.

In order to do this, it will be necessary to identify a set of indicators that can be used to assess the impact of uranium mining on the health and quality of life experienced by residents of northern communities. This will be a challenging undertaking, one that will almost certainly require professional assistance. The panel, therefore, welcomes and strongly commends the leadership of Cameco, one of the CLMC partners, 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. This initiative will be facilitated by the Department of Northern Affairs, through the Northern Mines Monitoring Secretariat, and in discussion with the emerging Northern Health Boards. Groups like the EQCs and the AWG might also play a role in the process. This initiative would undoubtedly enhance the health monitoring study which has been designed to identify health trends, past, present and future, in northern Saskatchewan. The first phase of the provincial study began in the fall of 1996. [Government of Saskatchewan, Submission to the McArthur River and Cigar Lake Public Hearings, Regina, Saskatchewan, September 4, 1996, p. 46.]

The panel heard various suggestions about ways in which community vitality could be enhanced or studied. For example, the Athabasca EQC suggested that communities and mining companies explore the possibility of joint bulk purchasing and transportation of dry goods, fuel, and construction supplies. The savings created by economies of scale could be shared. Such a suggestion shows a way in which the mining companies, government, and communities could work together to improve the quality of life of northerners, and should be carefully considered.

Some aspects of community health and its relation to uranium mining are being studied systematically. The cumulative health effects involving environmental pathways analysis and the monitoring of contaminants in a variety of VECs by the CEMWG have already been noted in Section 12.1. Saskatchewan Health has also completed a literature review on potential physical effects of uranium mining on adjacent human populations and is studying recommendations arising from this review. [Ibid, p. 45.]

A steering committee, comprised of federal and provincial government departments, northern communities, and industry, initiated a study of the feasibility of a comprehensive baseline health status survey. Based on its recommendations, Saskatchewan Health will facilitate a more detailed analysis of existing databases and of their possible use as indicators in a baseline health study. [Ibid, p. 46.]

Finally, an epidemiological study of the incidence of lung cancer and mortality of uranium mine workers in Saskatchewan has been announced. [Atomic Energy Control Board, Submission to the McArthur River and Cigar Lake Public Hearings, Regina, Saskatchewan, September 6, 1996, p. 5.] The proposed study is a cooperative venture involving the AECB, Saskatchewan Labour, Saskatchewan Health, and the mining companies. We strongly endorse this study, which will last for approximately thirty-five years. It should be given priority status, and appropriate funding should be made available to permit its long-term research goals to be achieved.

12.4 Conclusions and Recommendations

Information indicates that there has been no detectable regional contamination of the food web in northern Saskatchewan. Continuous monitoring and mitigation are necessary to protect it from deterioration as the region experiences development.

Local residents should be involved in all aspects of monitoring. The Environmental Quality Committees provide a good avenue for incorporating local wishes into decisions related to uranium mining activities in northern Saskatchewan. Adequate financial support should be provided to educate and train committee members in the various issues related to uranium mining and milling. The AECB should be more active in its EQC support and participation.

The activities of the Athabasca Working Group are to be encouraged; it is important that the mining companies and community representatives meet regularly to discuss issues of common concern.

Just as the monitoring of biophysical impacts requires the participation of professional biologists and chemists, the monitoring of impacts to community vitality requires assistance from social scientists. Cameco is to be commended for helping to fund this expertise and for linking it with community health.

The panel is encouraged by recent 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 epidemiological study of the incidence of lung cancer among uranium mine workers. Funds should be made available to ensure the continuation of these initiatives.

The environmental damage and potential social disruption caused by the Cigar Lake Project can be justified only if the project returns certain benefits to Canadian society. Although reasonable profits for the proponents are essential to the successful completion of this project, resource development is not justified unless it also brings benefits to Canadians in general and to local residents in particular. The major quantifiable benefits take two forms -- royalties/taxes paid to governments, and employment/business opportunities for citizens. Since local people must bear the greatest risk of environmental damage or social disruption, it is essential that a substantial share of the jobs and business activity created by the project remain in the north.

This chapter contains a discussion of the benefits from the Cigar Lake Project that might be expected to accrue to Canadians, in general, through government revenues, and to the residents of Saskatchewan's North, in particular, through employment and business opportunities.

13.1 Benefits to the People of Canada and Saskatchewan

13.1.1 Project Viability

A project that lacks economic viability is not likely to provide significant benefits. In fact, economic disbenefits associated with unmitigated environmental damage are likely to result from projects that are not economically sound. The province of Saskatchewan, therefore, included a viability assessment in its submission to the panel. [Jane Forster, Government of Saskatchewan, Opening Presentation, Cigar Lake Public Hearings, Regina, Saskatchewan, September 4, 1996, p. 7.] Noting that the Cigar Lake Project has one of the largest and richest uranium deposits known, the province concluded that it is expected to be among the most competitive uranium mining operations in the world. At capacity, it will be able to provide sufficient uranium to meet approximately 14 per cent of the annual world-wide production requirements.

Other factors which the province indicated would contribute to the economic viability of the Cigar Lake Project include:

• the existence of positive cash flows across the forecast price ranges;
• a predicted rate of return that is higher than the industry threshold for project viability;
• less than one chance in one hundred of economic failure, according to Monte Carlo simulation techniques used to evaluate a range of scenarios; and
• project owners (Cameco, Cogema, Idemitsu, TEPCO and KEPCO) that have expertise in uranium marketing and well-developed, long-term relationships with customers.

Based on the Department's analysis, we believe the project will be economically viable and will create significant benefits to the province and to the people of the North.

J. Forster, Province of Saskatchewan, Transcript of Cigar Lake Public Hearings, Regina, Saskatchewan, October 4, 1996, pp. 21-22.

13.1.2 Provincial Revenues

Provincial revenue from this project will be obtained in the form of royalties, capital taxes and surcharges, surface lease fees, property taxes, provincial sales taxes and income taxes. The level of public income that may be expected from this project will depend substantially on its profitability, which in turn will be directly dependent on the price at which the product, yellow cake, can be sold. Using various scenarios, as required by the Guidelines, the proponent has concluded that provincial revenues could be as high as $1.44-billion or as low as $1.00-billion. [The Cigar Lake Project Environmental Impact Statement, Additional Information II, Cigar Lake Mining Corporation, July, 1996, pp. 1-3 to 1-5.] The province provided an independent evaluation that was somewhat more conservative with respect to the predicted revenues. Based on an extensive analysis of world-wide uranium supply and demand, [Final Report, Saskatchewan Environment and Resource Management, May, 1996, Section 3, pp. 1-26.] the province concluded that revenues would be in the range of $595-million to $905-million. [J. Forster, Government of Saskatchewan, Opening Presentations, Cigar Lake Public Hearings, Regina, Saskatchewan, September 4, 1996, pp. 9-11.]

A comparison of the estimates provided by the proponent and the province has been made in Table 13.1. It can be seen that, in addition to predicting royalties that are about 20 per cent lower than those arrived at by the proponent's scenario, the province is expecting to receive much less revenue from sales taxes. The fact that the province lowered its sales tax from 9 per cent to 7 per cent after this estimate was made would cause a further decrease in the estimated revenues.

The proponent's estimate of revenue in Table 13.1 is also larger because all payroll taxes are taken as revenue to the province, whereas the provincial estimate was limited to income taxes. Although a breakdown of the amount included by the proponent is not given, it is our view that payroll deductions for programs such as Workers' Compensation should not be considered to be public revenue. Such programs add no incremental funds to the public treasury; they simply provide insurance for the employees that the proponent would have to purchase elsewhere if it were not available in its present form.

Despite the difference in the amounts predicted by the various scenarios, it is apparent that this project has the potential to make a substantial contribution to the provincial treasury.

Before concluding the discussion of potential provincial revenues from the Cigar Lake Project, it should be noted that income from the surface lease fees and property taxes does not go into the province's general revenue fund; it is transferred directly to the Northern Revenue Sharing Trust Account which provides funding for northern municipalities and school boards. [Final Report, Saskatchewan Environment and Resource Management, May, 1996, Section 2, p. 81.] A portion of the public funds derived from this project would therefore be of direct benefit to northern communities. However, as we have noted in a previous report, [D.G. Lee, J.F. Archibald, J. Dantouze, R. Neal and A. Yassi, McArthur River Underground Exploration Program, Supply and Services Canada, January, 1993, p. 4.] bands and persons who fall under the fiduciary responsibility of the federal government do not share in this fund, thus creating the possibility of inequities if the federal government does not also use some of its revenue from uranium mining to establish a similar fund for those communities under its jurisdiction.

13.1.3 Federal Revenue

The federal government will also receive substantial income from the Cigar Lake project. The proponent estimates that total revenue to the Government of Canada would be $665-million. These estimates, summarized in Table 13.2, include various payroll taxes such as CPP and EI which, in common with the provincial WCB fees mentioned in Section 13.1.2, provide no net benefit to the public treasury. Table 13.2 also includes $25-million for services provided by the AECB which fall into the same category. It appears, therefore, that the net federal income attributable to the Cigar Lake project would be somewhat less than the $665-million predicted in Table 13.2.

The province made a point of noting that the AECB fees were deducted from the company's income before royalties were calculated. This has the effect of decreasing the funds that would flow from this project into provincial coffers.

More significant to the Province of Saskatchewan is the fact that those costs are deducted before the calculation of royalty payments and, as such, proportionately reduce the royalty payments paid by the industry to the province. Indirectly, the people of Saskatchewan are paying the costs for AECB's regulation of uranium mining in Saskatchewan.

T. Penikett, Government of Saskatchewan, Transcript of Cigar Lake Public Hearings, Regina, Saskatchewan, September 4, 1996, p. 7.

13.2 Benefits to Residents of Saskatchewan's North

13.2.1 Education and Training

Because current uranium mining practices rely heavily on modern technology, many of the jobs associated with the Cigar Lake Project would require considerable education and technical training. The main vehicle through which northerners can acquire the skills required to capture a significant portion of the jobs at Cigar Lake and other sites is the Multi-Party Training Plan. The objective of this plan is "to provide training that will enable residents of northern Saskatchewan to take advantage of new job opportunities and to compete for available vacancies that are being created through mining development in the province's north". [Multi-Party Training Plan, Northern Education Services Branch, Province of Saskatchewan, August, 1996, p. 2.] It does this by providing training-to-employment opportunities in cooperation with some of the mining companies, including Cameco Corporation, Cogema Resources Inc. and the Cigar Lake Mining Corporation. Other participants in the plan are Northlands College; the Prince Albert Grand Council; the Meadow Lake Tribal Council; Saskatchewan Post-Secondary Education and Skills Training; Human Resources Development, Saskatchewan Region; Jim Brady Development Corporation (Métis Authority); Saskatchewan Economic Development; and the Provincial Apprenticeship Board. This five-year, $10.5 million plan, which was announced as part of the province's response to a previous report from the panel, [The Government's Position on Proposed Uranium Mining Developments in Northern Saskatchewan, Government of Saskatchewan, December, 1993, pp. 31-32.] has been highly successful but will end in 1998. The province reported on October 4, 1996, that the partners in the Multi-Party Training Plan had invested $6.7-million which had enabled 544 individual students to participate. To that date, more than 300 training certificates had been awarded and 284 northerners, most of aboriginal ancestry, had gone on to full-time or seasonal employment, 76 per cent in mining-related work. [R. McKay, Government of Saskatchewan, Transcript of Cigar Lake Public Hearings, La Ronge, Saskatchewan, October 2, 1996, p. 70.]

The province also described efforts undertaken to improve science and mathematics education in northern K-12 schools and a new SIAST environmental engineering technology program that is expected to result in graduates being recognized as Applied Science Technologists. [Ibid., pp. 12-13.] Cameco Corporation, which will become the operator of the Cigar Lake Project if it is approved, also announced initiatives that would assist more northern students to enter university engineering programs. [B. Michel, Cameco Corporation, Transcript of McArthur River and Cigar Lake Public Hearings, La Ronge, Saskatchewan, October 2, 1996, p. 129.]

A final important initiative by the province is the attempt to incorporate the traditional knowledge of northern peoples into the training delivered. For example, a new Environment/Resource Management Certificate program is being developed in cooperation with several Aboriginal post-secondary training institutions, including the Saskatchewan Indian Federated College, the Saskatchewan Indian Institute of Technologies, Dumont Technical Institute, Northlands College and SIAST-Woodland. The insights acquired by northern people through centuries of living in harmony with the natural environment must be retained and included in any education designed to prepare residents of Saskatchewan's North for life in the twenty-first century.

It is clear that education and training are the keys to enabling northern people to benefit from resource development, including mining. Basic education, including improved literacy skills and computer training, should be as easily available in the north as in the southern part of the province. Efforts to improve the K-12 and college programs must continue and sufficient training-to-employment should be provided to ensure that a qualified northerner is available for each job opening created if the Cigar Lake Project is approved.

It is recommended that the Multi-Party Training Plan be renewed or replaced by an alternative, improved vehicle for training-to-employment when its current mandate expires. The good start that has been made under the auspices of the Multi-Party Training Plan must not be wasted by failure to capitalize on the successes that have been achieved to date. The cooperation between the province and the industry to provide training that approximately matches the employment opportunities available is an outstanding example of the way in which benefits from resource development can be maximized for local residents.

13.2.2 Employment

The Cigar Lake EIS indicates that employment opportunities will occur in two phases if the project is approved. The first phase, construction, will require approximately 270 employees and last for about two years. The second phase, production, will require 200 employees and last for an estimated 39 years. [The Cigar Lake Project Environmental Impact Statement, Supporting Document No. 8, Cigar Lake Mining Corporation, July, 1995, pp. 4-8.] Milling of Cigar Lake ore will also add 38 employees at the JEB site and extend the employment of 129 workers for an additional 25 years. [The Cigar Lake Project Environmental Impact Statement, Main Document, Cigar Lake Mining Corporation, July, 1995, p. 19-5.] In the present climate, where high unemployment is endemic, long-lasting jobs must be considered as one of the major benefits of the project, particularly if the majority of the employees are from northern Saskatchewan.

The Cigar Lake EIS states that, "residents of the Athabasca region of northern Saskatchewan will receive first priority consideration when filling vacant positions at the sites. Vacancies not filled from the Athabasca region will be open to other residents of Northern Saskatchewan. Vacancies not filled from northern Saskatchewan will be open to other residents of Saskatchewan and Canada." [Ibid., pp. 19-5 to 19-6.] In addition, during public hearings on the McArthur River project, Cameco Corporation (which has been designated as the operator of the Cigar Lake project, should it be approved) made a number of commitments with respect to its workforce at the McArthur River mine and the Key Lake mill. Through these undertakings, described in detail in a previous panel report, [D.G. Lee, J.F. Archibald and R. Neal, McArthur River Uranium Mine Project, Supply and Services Canada, February, 1997, pp. 6 - 7.] Cameco made three primary commitments with respect to employment opportunities and its employees. In summary, these are:

• a commitment to a policy of maximizing the opportunities for residents of northern Saskatchewan to fill any positions that become available;
• a commitment to the development and implementation of a comprehensive education and training plan for all employees; and
• a commitment to various measures to enhance on-site services available to their employees.

Although these commitments were made for another project, they should also apply at the Cigar Lake site. It is, therefore, essential that project approval include a requirement that employment commitments similar to those Cameco has made for the McArthur River project also apply to the Cigar Lake project. Furthermore, it is recommended that Cameco be held publicly accountable for these undertakings by inclusion in the surface lease of provisions that requires it to report annually to the province on progress made on the implementation of each of these commitments.

The Cigar Lake EIS states that northern employment is expected to reach "about 50% within five years of operations start-up". [The Cigar Lake Project Environmental Impact Statement, Supporting Document No. 8, Cigar Lake Mining Corporation, July, 1995, pp. 4-8.] We find this to be an unacceptably low expectation in light of the funds and efforts that have gone into preparing northerners for mine work and the commitment made by the proponent to maximize northern participation in its workforce. We believe that it should be possible to have a minimum of 50 per cent northern employees from the beginning of the project. Approval to proceed should be granted only with the condition that the proponent maintain a minimum of 50 per cent northern participation in its workforce at all times. Furthermore, it is recommended that the employment objective for northern participation in the workforce be increased by 1 per cent per year until it reaches at least 67 per cent. Sixty-seven per cent has been identified as the target because it appears to be an objective that is attainable, while at the same time requiring the proponent to remain committed to maximizing northern participation. It is also consistent with participation objectives that have been supported by the operators of other northern mines such as the BHP diamond mine [The Globe and Mail, " Mine Deal Would Secure Jobs for Natives ", October 21, 1996, p. 1A (Western Edition).] in the Northwest Territories and the McArthur River uranium mine. [McArthur River Report, Response to the Report of the Joint Federal-Provincial Panel, Cameco Corporation, April 2, 1997, p. 10.]

13.2.3 Business Opportunities

The Cigar Lake project will provide numerous business opportunities associated with the provision of goods and services. The proponent has stated that it is its intention "to provide first priority for new business opportunities to businesses from the Athabasca region communities" and secondary priority to businesses located in other parts of northern Saskatchewan. [The Cigar Lake Project Environmental Impact Statement, Additional Information II, Cigar Lake Mining Corporation, July, 1996, Table 1.3.1.] While this is a laudable commitment, the proponent then goes on to estimate that out of a total requirement of $1.87-billion only $338-million (18 per cent) would be obtained from northern Saskatchewan. This estimate is very low, especially when compared to Cameco's report that 42 per cent and 30 per cent of its goods and services were purchased in the north in 1995 and 1996, respectively. [McArthur River Project, Response to the Report of the Joint Federal-Provincial Panel, Cameco Corporation, April 2, 1997, pp. 9 - 10.] A goal of obtaining an average of at least 35 per cent of all goods and services from northern suppliers would be more justifiable. Further, with the increase in northern business acumen anticipated over time, it would not be unreasonable to expect this percentage to gradually increase over the projected 40-year life of the project.

Because northern business opportunities are among the most significant socio-economic benefits to be derived from this project, the proponent should be monitored to ensure that northerners are being given the priorities promised in the EIS. To ensure that the proponent is following through on its commitments, the surface lease should include provisions requiring the operator to report annually to the Government of Saskatchewan on its progress with respect to the acquisition of goods and services from northern business.

13.3 Conclusions and Recommendations

The Cigar Lake Project will likely be economically viable and produce substantial public revenues for the Governments of Canada and Saskatchewan. It is also expected that revenues derived from surface lease fees and property taxes would contribute approximately $33-million to the Northern Revenue Sharing Trust Account.

It is recommended that the Multi-Party Training Plan be renewed or replaced by an alternative, improved vehicle for training-to-employment, when the current agreement expires.

It is recommended that the employment objective for the participation of northerners in the mine workforce be set initially at 50 per cent and increased by 1 per cent per year until it reaches at least 67 per cent.

It is recommended that the surface lease include an objective of obtaining at least 35 per cent of the required goods and services from northern suppliers, with the expectation of gradual increases during the lifetime of the project.

It is recommended that the surface lease include provisions for the Cigar Lake Project that require the operator to report annually to the Government of Saskatchewan on the progress being made with respect to northern employment and business objectives.

14.1 Northern Participation in Regulatory Agencies

The government agencies responsible for regulating the mines have very low northern participation in their work forces. Although the mining industry is required to maximize northern employment, the regulatory agencies do not appear to have taken this as a serious responsibility for themselves. Greater employment participation by northerners would facilitate community consultation, thereby enhancing the credibility of regulatory agencies in the impact communities, and increasing the opportunities for finding northern solutions to northern problems. It is recommended, therefore, that federal and provincial agencies providing regulatory services for the northern mines adopt human resource objectives for themselves that result in an increased participation by northern residents in the regulatory work force, comparable to the expectations for the mining industry.

Failure to take this recommendation seriously could produce a situation where northerners attempt to establish agencies of their own in which they would have more confidence. For example, in a letter commenting on a previous panel report, the Prince Albert Grand Council stated that, "the continuation of advisory roles for northerners on environmental issues is totally inadequate. We require an independent environmental protection and monitoring capacity, with full decision-making participation in northern Saskatchewan". It would be far better to have one integrated regulatory system that everyone trusts than a fragmented arrangement in which each interest group attempts to do its own monitoring of environmental impacts.

We would like from our own standpoint to conduct our own environmental review process, we would like to make sure that the mining companies or forestry companies or people who are proposing any type of development pass our requirements in terms of how those activities can happen...

A. Adam, Vice Chief, Federation of Saskatchewan Indian Nations, Transcript of Cigar Lake Public Hearings, Saskatoon, Saskatchewan, September 19, 1996, p. 120.

14.2 Revenue Sharing

It is evident from their words and actions that northern leaders wish to have the issue of revenue sharing resolved in a political forum rather than as part of an environmental review process. We agree with that approach and encourage the participation of both levels of government in a multipartite discussion of revenue sharing with northern leaders.

In a previous report, we noted that the issue of revenue sharing is broader than most others that have been dealt with in this review process and urged that the governments jointly initiate discussions with northern leaders on the implementation of a program of revenue sharing. Although not all northern communities participated in the review, most seemed to favour this approach in their formal responses to the report. Max Morin, writing on behalf of the Saskatchewan Association of Northern Communities, attached a resolution "fully supporting the panel's recommendations". The Prince Albert Grand Council's response, submitted by Vice Chief John Dantouze, stated that they were encouraged by the panel's recommendation on revenue sharing, and Blaine Favel, Chief of the Federation of Saskatchewan Indian Nations, commented that "The FSIN strongly supports this recommendation and the acknowledgement that resource royalty revenue-sharing should not be specific only to the uranium industry but more generally to resources in the province of Saskatchewan". It appears from these comments that there is almost universal acceptance in northern Saskatchewan of the idea that a cooperative effort should be made to develop a workable program of revenue sharing.

In response to a previous report, representatives of the Government of Saskatchewan met with northern leaders on May 12, 1997 to discuss revenue sharing and related issues. [Government and northern leaders meet to discuss northern issues, News Release, Executive Council, Government of Saskatchewan, May 12, 1997.] Following that meeting, it was announced that the Province had entered into a tripartite agreement with Canada and the FSIN to negotiate fiscal arrangements on several related financial issues, including revenue sharing. [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, p. 4.] We commend the participants on this agreement and urge them to proceed as quickly as possible to a resolution of these issues. To be effective, any program of revenue sharing should be implemented before the resource is further depleted.

14.3 Public Participation in Future Planning

Many of the environmental impacts of this project cannot be predicted with certainty in advance. Although the current plans for this mine have been reviewed in detail with full public participation, there will be a need for continual planning and monitoring. If the operators expect, as they have indicated, to develop this project in harmony with the wishes of northern people, continued northern participation in the planning process will be required. Such participation should be at an early enough stage to influence decisions. It is not sufficient to explain why a decision was taken, after the fact. It is clear that northerners wish to be involved at a much earlier stage in the planning processes.

The Environmental Quality Committees and the Athabasca Working Group provide avenues through which public participation can be solicited on a routine basis. Meaningful communication between the operators, the Environmental Quality Committees and the Athabasca Working Group is essential, as is the need for periodic community meetings.

14.4 Harmonization of Regulations

Both the provincial and federal governments have responsibilities for licensing and regulating uranium mining, a fact which the public and the industry find confusing and inefficient. Although each government department has a specific mandate, it often appears that there is overlap between the departments, and between governments.

In responding to a recommendation in a previous panel report, Cameco stated that, "Anything that can be done to reduce duplication in effort between the province and the federal agencies, including more agencies than just the AECB, would be beneficial by simplifying an overly complex set of regulatory requirements and reporting schemes. This should improve safety in the operations by allowing staff to devote more time to safety activities and less to duplicated inspections and reporting activities". [McArthur River Project, Response to the Report of the Joint Federal-Provincial Panel, Cameco Corporation, April 2, 1997, p. 17.] The public's demand for assurance that there be adequate protection in place to safeguard health and protect the environment also requires a less complicated, more transparent regulatory system.

Furthermore, at a time of scarce public resources, cooperation is a practice that governments can ill-afford to neglect. It would not only reduce red tape for the operators of the mine, but also make it easier for interested members of the public to understand and evaluate the impacts of the mines.

Harmonization of federal and provincial regulations would reduce confusion and increase efficiency; it is an appropriate long-term goal. Initiatives presently being undertaken by federal and provincial officials to eliminate overlap and regulatory duplication, under the Efficiency of the Federation Initiative, are encouraging and should be continued.

14.5 Cost Recovery of AECB Fees

One respondent to a previous panel report has suggested that the contributions Cameco and Cogema make to the Government of Canada for AECB regulatory services detract from the apparent objectivity and independence of the Board, and concluded that it is, "No wonder that there have been few interventions by the AECB in uranium mining operations in Sask." [Bill Adamson, letter of comment on the panel report on the McArthur River Project, March 14, 1997, p. 6.] Although the principle of cost recovery is well-understood, the use of this approach for the financing of regulatory agencies can create the impression that they are no longer independent.

JOINT FEDERAL-PROVINCIAL PANEL ON URANIUM MINING DEVELOPMENTS IN NORTHERN SASKATCHEWAN
-- CIGAR LAKE PROJECT --

• Dr. Donald Lee, Chariperson
• Dr. James F. Archibald
• Dr. Richard Neal

DONALD LEE (Chairperson)

Dr. Lee is Professor of Chemistry at the University of Regina and past President of Luther College. A native of Saskatchewan, he has a Master of Arts degree from the University of Saskatchewan, a Ph.D. in Chemistry from the University of British Columbia and has completed postdoctoral studies at Harvard University. Dr. Lee has been a member of the faculty at the University of Regina since 1967 and has served as a visiting professor at the University of North Carolina, Stanford University and the University of Oslo. He has published over ninety scientific papers and numerous non-scientific articles.

Active in community affairs for many years, Dr. Lee has been Chairman of the Saskatchewan section of the Chemical Institute of Canada, Executive Member of the Saskatchewan Association of Independent Schools, a national official of the Canadian Amateur Swimming Association, and President of the Regina Optimist Dolphin Swim Club.

JAMES F. ARCHIBALD

Dr. Archibald received his Ph.D. in Mining Engineering at Queen's University and is a Professor and Acting Head of the Department of Mining Engineering at Queen's. His work experience is primarily in the academic field and includes associated private consultation with national and international mining organizations. Dr. Archibald is a member of the Canadian Institute of Mining and Metallurgy (CIM), the CIM Backfill Sub-Committee (Rock Mechanics Group) and the American Institute of Mining Engineers.

Dr. Archibald's research interests include measurement and control of radiation hazards in underground mines, mine ventilation systems, in-situ stress analysis, rock burst prediction and structural mine design evaluation. Dr. Archibald is a member of the Nuclear Fuel Waste Management and Disposal Scientific Review Group examining the concept of deep geologic disposal of nuclear fuel waste.

RICHARD NEAL

Dr. Neal is Professor of Biology and Associate Dean (Academic) of the College of Arts and Science, University of Saskatchewan. He received both his Bachelor of Science and Ph.D. in Zoology from the University of Southampton, U.K. Dr. Neal has been a member of the Department of Biology at the University of Saskatchewan since 1968, and has taught extensively in the field of biology.

Dr. Neal's research interests include population ecology and a broad range of environmental issues, including impacts of uranium, potash and molybdenum mines and effects of pesticides on prairie ponds and duck populations. Dr. Neal is actively involved in a number of professional organizations and has been the Chairman of the Environmental Advisory Committee of the City of Saskatoon.

TERMS OF REFERENCE FOR THE ENVIRONMENTAL ASSESSMENT REVIEW OF URANIUM MINING DEVELOPMENT

MANDATE

1. The Panel shall review the environmental, health, safety and socio-economic impacts (hereinafter referred to as "impacts") of the proposed uranium mine developments (listed in Schedule A) in Northern Saskatchewan and assess their acceptability.

In assessing the acceptability of the proposed developments, the Panel will include in its review and consider:

1. the historical experience with past and existing uranium mining operations in Saskatchewan;
2. the cumulative impacts of existing operations and the proposed developments;
3. the short and long term impacts of the proposed projects, spanning their construction phase, operating period, decommissioning phase and post-decommissioning phase;
4. the impact of employment and socio-economic opportunities afforded northern residents by the proponents and the measures necessary for implementation of those opportunities;
5. the adequacy of measures proposed by the project proponents to protect environmental quality and to safeguard worker health and safety, and whether the measures can be expected to meet the requirements of Canadian and Saskatchewan law, regulations and policies applicable to uranium mine developments;
6. the adequacy of monitoring, enforcement and compliance systems to ensure that measures necessary for mitigating adverse impacts can be implemented;
7. the benefits afforded by the proposals.

2. The Panel shall determine from its review whether a project is acceptable or unacceptable.

In concluding that a project is acceptable, the Panel may recommend that specified minimum terms and conditions, including any mitigative measures or any other measures relating to the impacts under the Panel's review, be implemented where it considers these necessary for the protection of health, safety and the environment or for dealing responsibly with socio-economic concerns. The Panel may also suggest measures that it considers would enhance the acceptability of the proposals.

If the Panel concludes a project is unacceptable, it shall provide its reasons for this conclusion.

3. In fulfilling its mandate, the Panel shall provide full opportunities for public consultation and review.

REVIEW PROCEDURES

Detailed written procedures for conducting the review shall be established by the Panel and made available to the public.

TECHNICAL EXPERTS

The Panel may secure the services of independent technical experts to assist and advise on complex technical and/or socio-economic issues related to its mandate. Such experts will also be available to respond to inquiries from review participants.

STAGES OF THE REVIEW

Schedule A lists the five proposals to be reviewed by the Panel. The five proposals have been referred due to potentially significant or unknown adverse environmental effects and public concern.

While all of the proposals are in the planning stage, some are further advanced than others. Environmental Impact Statements (EIS) have been prepared for the first three proposals listed in Schedule A, one of which (Dominique-Janine Extension) is associated with the existing operating uranium mining facility and two of which are for new uranium mining facilities. EIS documents have yet to be prepared for the last two proposals listed in Schedule A. The Panel will take the differing stages of these projects into consideration in scheduling its review.

The Panel will seek public comment on the three available EIS's and determine their adequacy before proceeding to public hearings. When the Panel is satisfied with the information provided, including that with respect to the cumulative impacts, it may report on one or more of these projects to the Ministers as described in the following stages of the review. The Panel shall submit its final report(s) on these proposals within 18 months of its appointment.

In reviewing the remaining two proposals, the Panel will conduct scoping sessions in appropriate communities to solicit public comment and, based on these comments and its own consideration, prepare and issue Guidelines to the respective proponents for the preparation of EIS's. The cumulative impacts of these two proposals will be considered when the EIS documents have been submitted. The stages of the review following submission of these documents to the Panel are outlined below. The Panel shall submit its final report(s) on these two proposals within 18 months of receipt of the proponent's EIS's.

1. Review of Information

1. Review of the available information on the environmental, health, safety and socio-economic impacts of the uranium mining industry in Saskatchewan to date. The information and any related reports prepared will be made available to the public.
2. Review of the past performance of the uranium mining industry in providing employment and socio-economic opportunities to northern residents. The information and any related reports prepared will be made available to the public.
3. Review by the Panel of the Environmental Impact Statements (EIS) submitted by the proponents. The EIS's will also be made available to the public for review and written comment.
4. The Panel may draw on proponents, technical agencies from within federal or provincial governments, independent experts and the public for available information.

2. Should the Panel, after reviewing the above information and considering public comments, deem an EIS deficient it may request additional information from the project proponent.

3. Once the Panel is satisfied with the information provided, it will announce public hearings for the project in question. If appropriate, the hearings may be structured to address more than one project.

For the purposes of promoting public awareness and facilitating public comment, the Panel will hold meetings and/or hearings in the appropriate northern communities, Regina, Saskatoon and in such other Saskatchewan communities as the Panel may think necessary.

4. When the Panel is in a position, following the completion of public hearings, to provide a report on its findings, conclusions and recommendations relevant to a specific project, it will submit the report to the federal Ministers of Environment and of Energy, Mines and Resources and to the Saskatchewan Minister of Environment and Public Safety.

The Panel should, to the extent possible, ensure that the timely review of a specific project is not jeopardized by delays in the review of another project included in its mandate.

LINKAGE TO OTHER POLICY PROCESSES

The Panel is not expected to interpret its mandate so as to duplicate the work of other public inquiries and policy processes or to focus on national or international issues which are not directly related to the impacts of the proposals.

However, concerns may be raised by the public which extend beyond the impacts of direct concern to the Panel, and in such cases the Panel will ensure that the public is provided a reasonable opportunity to express these concerns.

SCHEDULE A

EIS Submitted

1. Dominique-Janine Extension
   Amok Ltd.
2. South McMahon Lake Project
   Midwest Joint Venture (Denison Mines Ltd.)
3. McClean Lake Project
   Minatco Ltd.

EIS to be Prepared

1. McArthur River Project
   McArthur River Joint Venture (Cameco Corporation)
2. Cigar Lake Project
   Cigar Lake Mining Corporation

Joint public review announced and terms of reference issued by Robert de Cotret, Minister of the Environment, and Grant Hodgins, Minister of Saskatchewan and Public Safety, April 18, 1991

Joint review panel members appointed by Beattie Martin, Minister of Saskatchewan Environment and Public Safety, and Jean Charest, Minister of the Environment, August 22, 1991

Panel toured all proposed mine development sites, October 1-6, 1991

Panel's operational procedures released, December 19, 1991

EISs received and released for 90-day public review as follows:

• Midwest Joint Venture, December 19, 1991 (deadline date or submissions--March 20, 1992)
• McClean Lake Project, January 13, 1992 (deadline date for submissions -- April 13, 1992)
• Dominique-Janine Extension at Cluff Lake, March 31, 1992 (deadline date for submissions -- June 30, 1992)

Deadline date for public submissions for MJV and McClean Lake extended to May 29, 1992

Scoping meetings for Cigar Lake and McArthur River announced January 7, 1992, to begin February 7, 1992

Dates and locations of scoping meetings announced January 22, 1991, as follows:

• February 7, 1992 Ben McIntyre School, Uranium City
• February 8, 1992 Fond du Lac Band Hall, Fond du Lac
• February 10, 1992 Community Hall, Stony Rapids
• February 10, 1992 Community Hall, Black Lake
• February 11, 1992 Hatchet Lake Band Hall, Wollaston Lake
• February 12, 1992 Arena Hall, La Loche
• February 13, 1992 Complex Hall, Buffalo Narrows
• February 14, 1992 Community Hall, Ile-à-la-Crosse
• March 2, 1992 Ramada Renaissance, Regina
• March 3, 1992 Holiday Inn, Saskatoon
• March 4, 1992 Marlboro Inn, Prince Albert
• March 5, 1992 Kikinahk Centre, La Ronge

Modifications to the Midwest Joint Venture and McClean Lake projects issued May 6, 1992

Technical reviews of Midwest Joint Venture and McClean Lake projects, as prepared by Ecologistics Limited, released by the panel May 29, 1992

Draft guidelines for EIS preparation and government information requests for Cigar Lake and McArthur River issued June 1, 1992, for public review until July 3, 1992

Summary report on scoping meetings for Cigar Lake and McArthur River, prepared by Quadra Planning Consultants Ltd., released by the panel, August 19, 1992

Guidelines for the Preparation of Environmental Impact Statements and Government Information Requests for the Cigar Lake and McArthur Projects, issued September 11, 1992

Request for Additional Information issued to Amok Ltd. on October 7, 1992

Amendments for Midwest Joint Venture and McClean Lake EIS issued October 30, 1992, for a public review period ending November 30, 1992

EIS on McArthur River Project Underground Exploration Program, July 1992, and Addendum, October, 1992, referred to Joint Panel for public review on October 29, 1992, with review period ending December 2, 1992

Dates and locations for Public Hearings on McArthur River Underground Exploration Project announced November 1, 1992, as follows:

• December 3, 1992 Hotel Saskatchewan, Regina
• December 4-5, 1992 Holiday Inn, Saskatoon
• December 6, 1992 Community Hall, Fond du Lac
• December 7, 1992 Community Hall, Black Lake
• December 8, 1992 Hatchet Lake Band Hall, Wollaston Lake
• December 9, 1992 Community Hall, Pinehouse
• December 10, 1992 Kikinahk Centre, La Ronge

Total Minatco's response to panel's Request for Additional Information on the McClean Lake project released on December 15, 1992, for a public review period ending January 15, 1993

Panel released commissioned reports December 15, 1992, as follows:

• Health in the Context of Uranium Mining in Northern Saskatchewan, Ed Weick, ESAS
• An Overview of the Biophysical Environmental Impact of Existing Uranium Mining Operations in Northern Saskatchewan, Dr. Herman Dirschl, ESAS
• A Brief Historical Review of the Beaverlodge Mining Area of Northern Saskatchewan, R. Barsi and Dr. A.W. Ashbrook
• A Socio-Economic Overview of Uranium Mining in Northern Saskatchewan, Ed Weick, ESAS
• Review of the Cluff Lake and Key Lake Reports, L. Vigrass

Panel released Midwest Joint Venture's response to its Request for Additional Information on December 23, 1992, for a public review period ending, January 22, 1993

Panel released specialists' report, Assessing Cumulative Effects of Saskatchewan Uranium Mines Development, on January 8, 1993

Panel submitted McArthur River Underground Exploration Program report to federal and provincial governments on January 15, 1993

Cogema's (formerly AMOK) response to the panel's Request for Additional Information released February 8, 1993, for a public review period ending March 5, 1993

Public hearings dates and locations for Dominique-Janine, McClean Lake and Midwest Joint Venture proposals announced on February 19, 1993, with changes announced on March 26 and April 26, 1993. Hearings were held as follows:

• March 22-24, 1993 Hotel Saskatchewan, Regina
• April 13, 1993 Community Hall, Black Lake
• April 14, 1993 Hatchet Lake Band Hall, Wollaston Lake
• April 15-16, 1993 Kikinahk Centre, La Ronge
• April 16, 1993 Friendship Centre, Ile-à-la-Crosse
• April 19, 1993 Complex Hall, Buffalo Narrows
• April 20, 1993 Arena Hall, La Loche
• April 21, 1993 John M. Cuelenaere Library, Prince Albert
• May 3- 5, 1993 Holiday Inn, Saskatoon
• May 7- 8, 1993 Holiday Inn, Saskatoon
• May 17-20, 1993 Holiday Inn, Saskatoon

Panel submitted Dominique-Janine Extension, McClean Lake Project and Midwest Joint Venture, its report on those proposals, to federal and provincial governments on October 15, 1993

New proposal for development of the Midwest orebody, proposed by Cogema Resources Inc., referred by Sheila Copps, Minister of the Environment, and Berny Wiens, Minister of Saskatchewan Environment and Resource Management, November 9, 1994, to the joint panel

EIS on Midwest Project released for a 60-day public review August 31, 1995

EIS for the Cigar Lake proposal released October 4, 1995, for a 90-day public review

Public panel-proponent information meeting for the Midwest Project convened November 15-16, 1995, at the Legion Hall, La Ronge

Request for Additional Information on the Midwest Project issued to Cogema Resources Inc. by the panel on December 8, 1995

EIS for Cameco Corporation's McArthur River proposal released December 11, 1995, for a 90-day public review

Public panel-proponent information meeting for the Cigar Lake proposal held January 23-24, 1996, Legion Hall, La Ronge

Request for Additional Information issued to Cigar Lake Mining Corporation by the panel, February 20, 1996

Response to the panel's Request for Additional Information on the Midwest Project released on March 4, 1996, for a public review period ending March 18, 1996

Public panel-proponent information meeting for the McArthur River project held March 21-22, 1996, Legion Hall, La Ronge

Response to panel's Request for Additional Information from Cigar Lake Mining Corporation released on April 1, 1996, for a public review period ending May 1, 1996

Panel issued a second request for information on the Midwest Project to Cogema Resources Inc. on April 12, 1996 and received the supplementary information on May 13, 1996

Request for Additional Information issued to Cameco Corporation on the McArthur River proposal on April 17, 1996

Dates and locations for public hearings on the Midwest Project announced on April 25, 1996, as follows:

• May 27-31, 1996 Ramada Hotel, Saskatoon
• June 4- 5, 1996 Kikinahk Centre, La Ronge
• June 6, 1996 Fond du Lac Band Hall, Fond du Lac
• June 7, 1996 Black Lake Band Hall, Black Lake
• June 8, 1996 Father Megret School, Wollaston Lake
• June 10-12, 1996 Regina Inn, Regina
• June 13-15, 1996 Ramada Hotel, Saskatoon

Response to panel's Request for Additional Information from Cameco Corporation on the McArthur River proposal released on June 18, 1996, for a public review period ending July 18, 1996

Panel issued a second request for information on the Cigar Lake Mining Corporation on May 11, 1996 and received the supplementary information on July 18, 1996, for a 30-day public review period ending August 18, 1996

Dates and locations for public hearings on the Cigar Lake and McArthur River projects announced on July 18, 1996, as follows:

• September 4-6, 1996 Regina Inn, Regina
• September 9-18, 1996 Ramada Hotel, Saskatoon
• October 1-2, 1996 Kikinahk Centre, La Ronge
• October 3, 1996 Father Megret School, Wollaston Lake
• October 4, 1996 Community Hall, Stony Rapids
• October 5, 1996 Fond du Lac Band Hall, Fond du Lac
• October 7, 1996 Kateri Hall, Sandy Bay
• October 8, 1996 Band Hall Gymnasium, Montreal Lake
• October 9, 1996 Community Hall, La Loche
• October 10, 1996 Mezzanine, Beauval Arena, Beauval
• October 11, 1996 Community Hall, Patuanak

Additional public hearing session, September 19 in Saskatoon, announced on August 16

Panel announces reopening of Midwest review, and postponing of Cigar Lake technical sessions on tailings disposal, to permit public review of changed proposal for tailings disposal, August 26, 1996

Change to schedule for public hearings for the McArthur River and Cigar Lake proposals announced October 3; hearings held as follows:

• September 4-6, 1996 Regina Inn, Regina
• September 9-19, 1996 Ramada Hotel, Saskatoon
• October 1-5, 1996 Kikinahk Centre, La Ronge
• October 7, 1996 Community Hall, Pinehouse

Panel receives supplemental information on tailings disposal on October 31, 1996, and releases it for 30-day public review

Panel requests additional information on tailings disposal on December 12, 1996

Panel receives additional information from Midwest and Cigar Lake, and releases it for 30-day public review, on May 2, 1997

Public hearings on Midwest and Cigar Lake tailings disposal announced on June 16, 1997

Public hearings held on August 26-28, 1997, at the Kikinahk Centre, La Ronge, Saskatchewan

D-1 Oral Presentations Made at Public Hearings

• Abrahamson, Mervyn
• Adamson, W.R.*
• AGRA Earth & Environmental Limited (Andy Small)*
• Annie Johnstone Pre-School (Caroline Ratt, Hannah Natomagen)
• Association of Consulting Engineers of Saskatchewan (Phil Bruch)*
• Association of Professional Engineers of Saskatchewan (Henry Feldkamp, Dennis Paddock)*
• Athabasca Catering Ltd. Partnership (William Smith)*
• Athabasca Working Group (Chairperson Janet Holmgren, Georgina MacDonald, Councillor Margaret Powder, Mayor Victor Robillard)*
• Atomic Energy Control Board (Fred Ashley, Ken Bragg, Larry Chamney, Peter Courtney, Stan Isanen, Rick McCabe, Tom Viglasky)*
• BCP Engineering (Michelle Cabalt)*
• Beauval, Northern Village of (Deputy Mayor Elaine Malbeuf)*
• Belanger, Buckley
• Black Lake First Nation (Vice Chief Alan Adam, Elder Pierre Robillard, Chief Ron Robillard)
• Boyd, Laura
• Angus Butler Engineering (Jerry Helfrich)*
• Caisse, William
• CanAm Construction (Jean Poirier)*
• Canadian Coalition for Nuclear Responsibility (Gordon Edwards)*
• Canadian Nuclear Association (Murray Stewart)*
• Canadian Nuclear Workers Council (Dave Shire)*
• Carle, Gordon*Chambers, Dr. Doug
• Charles, Tom
• Chary, Dr. Srini
• Cigar Lake Mining Corporation (Gerry Acott, Ray Duret, Randy Knapp, Paul McKee, Jean-Luc Narcy, Lucien Nel, Barry Schmitke, John Tosney, Peter Vanriel)*
• Cogema Resources Inc. (Alain Marvy, Liz Quarshie)*
• Container Port of Saskatchewan (Jerry Hnatiuk)*
• Daigneault, Larry
• Dancer, Joys
• Dantouze, Vice Chief John*
• Environment Canada (Bill Howard, Dr. Dennis Lawson)*
• Environmental Quality Committees (Athabasca -- Victor Echodh, Jeanne Lepine, June MacDonald, Felix McDonald, George Tsannie; South- Central -- Bill Layman, Greg Ross, Pam Schwann; West Side -- Georgina Deschambault, John Janvier, Elaine Malbeuf, Mayor Max Morin, Clifford Ray, Norman Wolverine)*
• Federation of Saskatchewan Indian Nations (Vice Chief Alan Adam)*
• Fisheries and Oceans Canada (Bruce Fallis, Dr. Ray Hesslein, Dr. Jack Klaverkamp, Dr. Lyle Lockhart, Paul Wilkinson)*
• Flath, Tom
• Francis, Mai
• Fond du Lac First Nation (Chief Caroline Isadore)
• Fortugno, Maria
• Gabrush, Mayor Morris
• Golder Associates (Laurent Gareau)*
• Government of Saskatchewan (Jane Forster, Ray McKay, Tony Penikett)*
• Gurney, Penny*
• Hatchet Lake First Nation (Chief Emil Hansen)
• Haukley, Daryl
• Haynes, Stephen
• Hinds, Bob
• Indian and Northern Affairs Canada (Michel Blondin, Maurice LaFond)*
• Inter-Church Uranium Committee (Michael Poellet)*
• International Uranium Congress (Michelle Kowalski, Dan Parrott)*
• Jackson, Ted*
• Jackson, Tom
• JNE Welding (Jim Nowakowski)*
• Kilborn Western Inc. (Bruce Leech)*
• Kitsaki Development Corporation (Dave McIlmoyl)
• Kossick, Don
• Kramer Ltd. (Tim Kramer)*
• Kustiak, Cory
• LaLoche, Northern Village of (Deputy Mayor John Janvier)
• LaRonge/Air Ronge Economic Development Committee (Angus Pratt)*
• Lush, Don
• McCallum, Glen
• McNulty, Tom
• Métis Addictions Council of Saskatchewan (Hannah Natomagen)
• Mid-North Safety (Martin Arndt)*
• Millennium III Properties Corporation (Everett Kearley)*
• Natomagen, Clarence
• Natomagen, Roxanne
• Natural Resources Canada (Grant Feasby, Carmel Létourneau, Rennie Tupper, Bob Whillans)*
• Nature Saskatchewan (Garth Nelson, Curt Schroeder)*
• North Yanke Transfer Ltd. (Jerry Hnatiuk)*
• Northern Dene Airways Ltd. (Dave Webster)*
• Northern Health Services (Charlotte Ratt, Neil McLeod)
• Northern Resources Trucking (Dwayne Hounsell, Dave McIlmoyl, Roger Olyowsky)*
• Northlands College (Peter Mayotte, Bill McCallum)*
• Northwest Municipalities Association (Mayor Joe Daigneault, Mayor Max Morin)*
• O'Sky Yak Horizons (Leonard McCallum, Hannah Natomagen, Tom Sanderson)
• PCL Construction Management Inc. (Anibal Valente)*
• Penna, Angela
• Penna, Dr. James*
• Penna, Marion*
• Penna, Phillip*
• Peterson, Todd
• Plunz, Mike
• Points North Freight Forwarding Inc. (George Eikel)*
• Pinehouse, Northern Village of (Rene Rediron, Mayor Greg Ross)*
• Prince Albert Development Corporation (Trevor Ives)*
• Probert, Rodney
• Ratt, Charlotte
• Recovery Lake (Leonard McCallum)
• Sandy Bay, Northern Village of (Mayor Ina Fietz Ray)*
• Saskatchewan Association of Rehabilitation Centres (Carl Kwiatkowski)*
• Saskatchewan Chamber of Commerce (Jim Glass)*
• Saskatchewan Construction Association (Manley McLachlan)*
• Saskatchewan Energy and Mines (Jane Forster)*
• Saskatchewan Environment and Resource Management (William Caisse, Tom Gates, Rob Kidd, Malcolm Ross, John Schisler, Randy Sentis, Len Sinclair, Ron Zukowsky)*
• Saskatchewan Environmental Society (Ann Coxworth, Peter Prebble)*
• Saskatchewan Health (Dr. James Irvin)*
• Saskatchewan Highways (Stu Armstrong)*
• Saskatchewan Labour (Brian Allan, Dr. Ernest Becker, Jeff Parr)*
• Saskatchewan Mining Association (Bob Cunningham)*
• Saskatchewan Northern Affairs (Ray McKay, Richard Turkheim)
• Saskatchewan Northern Mines Monitoring Secretariat (Pam Schwann)
• Saskatchewan Risk Assessment Association (Dr. Ralph Cheesman)*
• Saskatchewan Uranium Coalition (Dr. Marvin Resnikoff)*
• Saskatoon Chemicals Ltd. (Bob McLeod)*
• Saskatoon City Hospitals Foundation (Randy Kershaw)*
• Saskatoon and District Chamber of Commerce (Kenneth Ziegler)*
• Saskatoon Regional Economic Development Authority (John Hyshka)*
• Septre Controls (Larry Bohn)*
• Shearer, Craig
• Shiell, Maisie*
• Shumard, Shirley
• Simpson, Graham
• Sinclair, Neil*
• Smith, Fred
• Smith, Martin
• Snake Lake Construction (Rene Rediron)
• Steinhäusler, Dr. Fritz
• Stilborn, Dan
• Stomp, Mayor Gordon
• Strnad, J.G.*
• Swider, Richard*
• Synergy Today (Rob Phillips)*
• Taylor, A.S.*
• Thomas, Dr. Pat*
• Tinker's Enterprises (Philip Tinker)
• Tippo Forrest Products (Glen McCallum)
• TriKon North General Contractors Ltd. (Ron Hemeon)*
• United Steel Workers of America (Ken Neumann, Gordon Telfer, Bernie Welke)*
• Uranerz Exploration and Mining Limited (Gerhard Ruhrmann, Al Shpyth)*
• Van Waters & Rogers (Lionel DeBray)*
• Weingeist, Karen*
• West Wind Aviation (Chris Tabler)*
• Wood, Lee
• Workplace Education Consortium of Saskatchewan (Phyllis Ramsden)*
• Young, Tom

*A written submission was supplied to accompany the oral presentation, and is available for public review.

D.2 Written Submissions

• Barbour, S. Lee
• Government of the Northwest Territories (Andrew Galble)
• Lawrence, Steve
• Meadow Lake Tribal Council
• Northwest Métis Development Corporation (Norm Johnson)
• Points North Construction Ltd. (Bob Westgard)
• Thyssen Mining Construction of Canada Ltd. (Volker Ebert)

• Guidelines for the Preparation of Environmental Impact Statements and Government Information Requests for the Cigar Lake and McArthur River Projects, Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan, September, 1992.
• The Cigar Lake Project Environmental Impact Statement, Cigar Lake Mining Corporation, July, 1995.
• Request for Additional Information on the Cigar Lake Project, requested by the Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan, February 20, 1996.
• Response to Request for Additional Information on the Cigar Lake Project, Cigar Lake Mining Corporation, March, 1996.
• The Cigar Lake Project, Request for Additional Information, requested by the Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan, May 22, 1996.
• The Cigar Lake Project, Additional Information II, Cigar Lake Mining Corporation, July, 1996.
• Addendum to the Cigar Lake Project Environmental Impact Statement, Cigar Lake Mining Corporation, October, 1996.
• Request for Additional Information on the Cigar Lake Addendum, requested by the Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan, December, 1996.
• The Cigar Lake Project, Tailings Management -- Additional Information, Cigar Lake Mining Corporation, April, 1997