Federal Environmental Assessment and Review Process

INIS-CA—0062

CA9800083

Federal Environmental
Assessment Review Office

RABBIT LAKE
URANIUM MINING
A-ZONE, D-ZONE,
EAGLE POINT

Canada
Federal Environmental Assessment and Review Process

Federal Environmental
Assessment Review Office

RABBIT LAKE
URANIUM MINING
A-ZONE, D-ZONE,
EAGLE POINT

Report of the
Environmental
Assessment Panel

November 1993

Canada
©Minister of Supply and Services Canada 1993
Cat. No. En105-51/1993E
ISBN 0-662-21162-6
 RABBIT LAKE URANIUM MINE
ENVIRONMENTAL ASSESSMENT PANEL

The Honourable Sheila Copps

Minister of the Environment
House of Commons
Ottawa, Ontario
K1A 0A6

The Honourable Anne McLellan

Minister of Natural Resources
House of Commons
Ottawa, Ontario
K1A0A6

Mr. J.G. McManus

Secretary General
Atomic Energy Control Board
Ottawa, Ontario
K1P5S9

In accordance with the terms of reference issued in November 1991, the Environmental
Assessment Panel has completed its review of the proposed development of the uranium
mining facility at Rabbit Lake in northern Saskatchewan. On behalf of the panel, I am
pleased to submit this report for your consideration.

Yours sincerely,

K. Wayne Hindmarsh
Chair
Rabbit Lake Uranium Mine
Environmental Assessment Panel
 TABLE OF CONTENTS
Page

EXECUTIVE SUMMARY 1

1 INTRODUCTION 3
1.1 Project Description 3
1.2 Review Process '. 3

2 OVERALL PROJECT FINDINGS, CONCLUSIONS AND

MAJOR RECOMMENDATIONS 7

3 PROJECT ENGINEERING ISSUES 11

3.1 Waste-rock Management 11
3.2 Tailings Management 12
3.3 Decommissioning 13
3.4 Water Use 15
3.5 Safety of Eagle Point Mine 16

4 ENVIRONMENTAL ISSUES 17
4.1 Observations on the Monitoring Program 17
4.2 Responsibility for Monitoring 17
4.3 Baseline Studies 18
4.4 Monitoring 19
4.5 Research Requirements 20
4.6 Cumulative Impacts 20

5 SOCIOECONOMIC ISSUES 21
5.1 Employment 21
5.2 Other Economic Benefits to Athabasca Basin Communities 21
5.3 Trapper Compensation 22
5.4 Quality of Working Life 22
5.4.1 Training 22
5.4.2 Work Schedules 23
5.5 Proponent-Community Relations 23

6 HEALTH AND SAFETY ISSUES 25

6.1 Community Health 25
6.1.1 Definition of Health 25
6.1.2 Northern Community Concerns 25
6.1.3 Radiation Risks 26
6.2 Worker Health and Safety 26
6.2.1 Health and Safety Programs 26
6.2.2 Radiation Risks 26
6.2.3 Effects of Radiation Exposure 27

7 MONITORING, ENFORCEMENT AND COMPLIANCE ISSUES 29

7.1 Regulations and Guidelines 29
7.2 Spills 29
7.3 Fish Habitat Compensation 30
7.4 Financial Security 30
8 OTHER ISSUES 33
8.1 Public Review Process 33
8.2 Provincial Issues Raised 34

9 RECOMMENDATIONS 35

APPENDICES
Appendix A: Panel Member Biographies 39
Appendix B: Secretariat and Technical Specialists 40
Appendix C: Terms of Reference 41
Appendix D: Bibliography of Review Documents 42
Appendix E: Schedule of Public Hearings 43
Appendix F: Submissions to the Panel 43
Appendix G: Glossary 45
 Executive Summary 1

EXECUTIVE SUMMARY
In November 1991, a federal environmental assessment orebodies not proceed until the required studies are com-
panel was appointed to examine the environmental, health, pleted and the specific issues identified in the report are
safety and socioeconomic impacts of the proposed develop- resolved.
ment of uranium mining at Rabbit Lake in northern Saskatche-
wan. The proposal involved two open-pit operations in the
It is clear to the panel that greater public involvement in the
Collins Bay A-zone and D-zone and full-production under-
regulatory regime governing the Rabbit Lake operation is im-
ground mining at Eagle Point.
perative to restore public trus^ in the process. Creation of an
The panel held public hearings on the proposal in June and Environmental Management Committee with members from
July 1993. This report is based on submissions made at the the public, including Athabasca Basin communities, and gov-
hearings and on other public documents presented to the ernment is an essential means to achieve this goal. The com-
panel. mittee would provide valuable advice on key engineering and
environmental issues, such as designing and implementing
This report to the Minister of Natural Resources and the Minis- the monitoring program. The panel concludes that establish-
ter of the Environment addresses the acceptability of the pro- ment of an Environmental Management Committee is an es-
posal in light of its environmental and socioeconomic impacts. sential condition of approval and recommends that the AECB
The conclusions and recommendations that the report take immediate steps to form such a committee.
presents will assist the Atomic Energy Control Board (AECB)
in deciding whether to approve all or part of the proposal with The panel's overall review of current monitoring activities at
or without conditions attached. the Rabbit Lake site indicates that there is a need for a more
effective program that focuses on ecological systems. The
Full-production underground mining at Eagle Point would em- monitoring program would utilize scientific standards and
ploy techniques developed and tested during exploratory ac- quality control techniques to yield the data required to estab-
tivities at this site. The mining methods proposed are lish baseline conditions and to fully assess the short- and
consistent with safe operational standards and have the po- long-term environmental effects of the operation. The panel
tential to mitigate adverse environmental impacts. This fact, thus recommends that the Environmental Management Com-
as well as the safe and sound procedures practised at Eagle mittee, in collaboration with the AECB and the proponent,
Point to date, leads the panel to recommend that the AECB develop and implement this type of monitoring program.
approve full-production mining at Eagle Point. It must be
stressed that this approval should be subject to the conditions
detailed in the report. These conditions are designed to en- The proposal raises a number of socioeconomic issues, in-
sure that the mining is safe, environmentally benign and fully cluding job opportunities, economic benefits to Athabasca Ba-
monitored. sin communities, the quality of working life and proponent-
community relations. The panel addresses these issues in the
The information presented to the panel on waste-rock man- report and makes a number of proposals about them. There
agement and decommissioning plans for the A-zone and is, however, one concern that should be highlighted: the need
D-zone open-pit operations is insufficient to determine for improved relations between the proponent and the
whether the environmental effects of these operations are Athabasca Basin communities, especially Wollaston Lake.
acceptable. Comprehensive studies are required to yield the The panel notes that there has been progress in this area
data necessary for assessment of the plans. The panel there- recently; however, there is still ample room for greater efforts
fore recommends that mining of the A-zone and D-zone by the parties to foster a climate of trust and cooperation.

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 Introduction 3

1 INTRODUCTION
1.1 Project Description then be pumped out of the dyked area, and the orebodies
would be mined by conventional open-pit methods. It is esti-
The Rabbit Lake Joint Venture (proponent), an undertaking of mated that each orebody would be mined over one winter.
Cameco Corporation and Uranerz Exploration and Mining Initial plans are to place most of the waste rock from mining
Limited, is proposing to mine three new uranium orebodies at the A- and D-zones on an existing pile of waste rock from the
the Rabbit Lake operation in northern Saskatchewan. The B-zone (Figure 2).
proposal calls for full-production underground mining of the
Eagle Point orebody and open-pit mining of the Collins Bay The Rabbit Lake mill would process Eagle Point, A-zone and
A-zone and D-zone orebodies. D-zone ore. A by-product of the milling process is tailings,
which consist of finely ground rock and chemical precipitates.
The Rabbit Lake operation is on the western shore of Wollas- Tailings from milling B-zone ore have been placed in the
ton Lake, about 100 km west of the Manitoba border and 200 mined-out Rabbit Lake pit, which was converted to a tailings
km south of the Northwest Territories (Figure 1). The three containment facility. The proponent plans to dispose of tail-
orebodies are located along the northwest shore of Harrison ings from milling Eagle Point, A-zone and D-zone ore in the
Peninsula on Collins Bay (Figure 2). The closest community is same facility.
the Hamlet of Wollaston Lake (Hatchet Lake Band), 40 km
away on the eastern shore of Wollaston Lake. Water removed from the Rabbit Lake tailings pit and the three
new mines would be pumped to the mill and treated prior to
Rabbit Lake, the oldest operating uranium mining and milling discharge into Effluent Creek, which flows into Hidden Bay
facility in Saskatchewan, started producing ore from open-pit (Figure 2). Cameco has developed preliminary decommis-
mining of the Rabbit Lake orebody in 1975. Exploration of the sioning plans for the three new mining operations and the
area surrounding the Rabbit Lake orebody identified several Rabbit Lake tailings pit.
additional radioactive occurrences, including the Collins Bay
A-zone, B-zone and D-zone and Eagle Point deposits. Follow- 1.2 Review Process
ing completion of mining at the Rabbit Lake pit in 1984, open-
pit mining of the Collins Bay B-zone took place from 1985 to In 1987, Cameco submitted to federal and provincial regula-
1991. The Rabbit Lake mill is currently processing ore stock- tory agencies an Environmental Impact Statement (EIS) con-
piled from the B-zone mine. This ore supply is predicted to be cerning a project to mine three new orebodies. The project
exhausted by May 1994. was approved under the Saskatchewan Environmental As-
sessment Act on January 4, 1988. Subsequently, the Sas-
The Eagle Point deposit, 13 km north of the Rabbit Lake mill, katchewan government reviewed Cameco's submissions to
is largely under the bed of Collins Bay. Cameco plans to this review and on June 7, 1993, advised the panel that the
develop the Eagle Point orebody as an underground mine in project conformed with the terms and conditions in the ex-
three phases: engineering feasibility and approvals (phase 1); isting ministerial approval.
underground exploration and test mining (phase 2); and full-
production mining (phase 3). The first phase has been com- The Atomic Energy Control Board (AECB) is the federal
pleted, and test mining (phase 2) has been under way since agency responsible for the administration of uranium mining
1991. and processing. Following a review of the 1987 EIS, the
AECB determined that the environmental effects of the pro-
The test mining phase requires construction of an access posed developments were mitigable with known technology
ramp or decline, horizontal tunnels and a ventilation system. and, in April 1988, issued a licence for test mining of the Eagle
The proposed mining method is vertical blast-hole stoping Point orebody.
with delayed fill. This method involves opening a drift or
tunnel along the top of the orebody to reach the ore and a In April 1991, the federal Minister of Energy, Mines and Re-
second drift below to remove the ore. The drifts are con- sources (now Natural Resources) referred the proposed de-
structed in waste rock to reduce worker exposure to radiation. velopment of the uranium mining facility at Rabbit Lake to the
A large-diameter hole, or slot raise, is drilled through the federal Minister of the Environment for a panel review. The
orebody from the lower drift. The detonation of explosives in referral was made in accordance with Section 13 of the Envi-
the drilled blast holes breaks the ore into the slot raise, where ronmental Assessment and Review Process (EARP) Guide-
it collects at a draw point. To reduce worker exposure to lines Order due to public concern about the proposal.
radiation, the ore is hauled away using remote- controlled
scoop trams. After the ore is removed, the stope is filled with a In November 1991, the Minister of the Environment appointed
mixture of waste rock and cement to stabilize the ground and the. Rabbit Lake Uranium Mine Development Panel (panel).
supply wall support for adjacent stopes. Members of the panel were Dr. K. Wayne Hindmarsh (chair),
Dr. Dennis Lehmkuhl, Dr. Ronald Martin and Mr. Charles Pel-
The A-zone and D-zone orebodies are 12 and 10 km respec- ley. Their biographies are in Appendix A. Prior to the public
tively from the Rabbit Lake mill. Cameco plans to mine these hearings phase, Mr. Pelley resigned from the panel for medi-
orebodies using the same techniques that were employed for cal reasons. During the public hearings, Mr. Wayne Clifton
the B-zone orebody. Since these orebodies are largely under- provided technical advice on engineering issues pertaining to
water, dykes of interconnected, rock-filled, steel sheet-pile uranium mining. A complete list of members of the panel
cells would be constructed around each orebody. Water would secretariat and technical specialists is in Appendix B.
 FOND-DU-LAC
STONY RAPIDS

CLUFFLAKE

RABBIT LAKE WOLLASTON LAKE

(HATCHET LAKE BAND)

KEY LAKE
•

ALBERTA MANITOBA

SASKATCHEWAN
LLOYDMINSTER

SASKATOON

FIGURE 1 : LOCATION OF RABBIT LAKE OPERATION

 B-Zone
Open Pit
Mine Service
Complex

Ore & Special Waste

Waste Stockpile Rock
Stockpile

Wollaston
Lake

Collins
Creek

Waste Rock
Stockpiles Stockpile
Rabbit Lake Pit
Tailings Disposal
A
Mine Water
Pond

Former Tailings Pond

Effluent
Treatment
Facility
Precipitation
Ponds

Effluent
Creek

FIGURE 2 : RABBIT LAKE OPERATION

6 Introduction

The panel was asked to review the environmental, health, information. In response, Cameco issued an Addendum to
safety and socioeconomic impacts of the proposed develop- the EIS in March 1993. After a 30-day review period, the
ment. Specifically, the panel was to review the short- and panel determined that there was sufficient information to pro-
long-term impacts; the cumulative impacts of the existing op- ceed to public hearings. At the same time, the panel re-
eration and the proposed development; the employment and quested information on six additional areas. This request was
socioeconomic opportunities for northern residents; the ade- answered by Cameco's "Response to Panel Questions and
quacy of measures to protect environmental quality and to Concerns on the Addendum." A bibliography of the review
safeguard worker health and safety; the adequacy of monitor- documents is in Appendix D.
ing, enforcement and compliance systems; and the benefits
afforded by the proposal. Complete terms of reference for the The public hearings gave review participants an opportunity to
panel are in Appendix C. present their views, opinions and technical information on the
acceptability of the proposal. Thirteen days of hearings were
Following appointment of the panel, Cameco updated the held between June 8 and July 5, 1993 in Wollaston Lake,
1987 EIS and submitted it to the panel in June 1992. The Black Lake, Fond-du-Lac, La Ronge, Prince Albert, Saska-
panel provided a 105-day review period to allow the public, toon and Regina (Appendix E). The panel received more than
government agencies and technical specialists to study the 130 submissions during this phase (Appendix F).
EIS and provide comments. During this review period, the
panel held community meetings in Wollaston Lake, Stony This report is the final step in the panel review process. It
Rapids, Black Lake, Fond-du-Lac and Uranium City to de- provides the panel's findings, conclusions and recommenda-
scribe the review process to communities in the Athabasca tions to the federal Ministers of the Environment and Natural
Basin and to identify issues important to these communities. Resources.
In November 1992, after reviewing the EIS and considering
comments received, the panel issued a request for additional A glossary of terms used in this report is in Appendix G.
 Overall Project Findings, Conclusions and Major Recommendations 7

2 OVERALL PROJECT FINDINGS,

CONCLUSIONS AND MAJOR
RECOMMENDATIONS
During the course of this review the panel received informa- information on these aspects of the proposal are in "Project
tion on many aspects of the proposal, including aspects that Engineering Issues" (Section 3).
were outside its mandate. The major issues that the panel
addressed are discussed in the following sections: Project
Engineering Issues (3), Environmental Issues (4), Socioeco- The panel found that there are a number of unresolved issues
nomic Issues (5), Health and Safety Issues (6), and Monitor- related to the mining of the A-zone and D-zone orebodies. For
ing, Enforcement and Compliance Issues (7). instance, the characteristics of A-zone and D-zone waste rock
including contaminant levels and acid generation potential
have not been determined. Further, the proponent has not
This section presents the panel's overall project findings, con- been able to demonstrate that the existing B-zone pit and
clusions and recommendations on mining of the Eagle Point, waste-rock pile can be successfully decommissioned, yet has
A-zone and D-zone orebodies and on public involvement in proposed a similar decommissioning approach for A-zone and
this development. D-zone. The panel recognizes that Cameco has made a com-
mitment to address these issues. Nevertheless, the panel
must conclude that it has insufficient information to recom-
Project Engineering Issues mend whether mining of the A-zone and D-zone orebodies
should proceed. Requirements for specific information related
Mining has been conducted at the Rabbit Lake site since 1975 to the proposed A-zone and D-zone developments are in Sec-
and the proposed development would be an extension of an tion 3.
existing operation. Mining of the A-zone and D-zone orebo-
dies would use the same techniques as were used for the
B-zone orebody. The existing mill would process Eagle Point,
A-zone and D-zone ores, and the Rabbit Lake tailings pit Environmental Issues
would be used to dispose of tailings from the milling operation.
Although the technique proposed for Eagle Point would be a
Full-production mining at Eagle Point is unlikely to result in
new mining technique for the Rabbit Lake site, test mining
any significant disturbance to the surrounding environment
since 1991 has given Cameco considerable information on
since mining will be underground. The main environmental
environmental impact, the safety of the underground mine
issues related to this aspect of the development are tailings
structure, and the protection of workers from radiation risks.
disposal, continued flow of mill effluent into Hidden Bay and
decommissioning. Based on current and predicted perform-
Although information on the environmental effects of the
ance of the operation, the panel concludes that impacts are
Rabbit Lake operation is available, the prediction of long-term
either insignificant or mitigable. However, a comprehensive
potential impacts depends on modelling. For example, the
baseline study and monitoring program would be required to
selection of final waste-rock management options and decom-
confirm that these predictions are correct and to identify im-
missioning strategies and the prediction of contaminant trans-
pacts not predicted so that they could be addressed. The
port all depend on models. Two key issues related to
panel has concluded that there is insufficient information to
modelling at the Rabbit Lake site arose. First, the panel was
assess the environmental impacts of developing the A-zone
advised that information on the basic geology and hydroge-
and D-zone orebodies.
ology of the site was limited. As a result, the models were
often based on conservative assumptions and were not cali-
brated with site data. Second, in a number of cases, field The environmental monitoring program received considerable
results have not been used to validate the models. Given that attention at the hearings. Cameco used the results of its moni-
the site has been operational for more than 15 years, there toring program to support its claim that the operation has had
have been a number of opportunities to obtain the data neces- very little effect on the local environment. Further, this record
sary for model validation. formed the basis of its prediction that impacts of the proposed
developments would be minimal. Government agencies, envi-
The panel concludes that Cameco has demonstrated the abil- ronmental interest groups and northern communities criticized
ity to adequately manage the proposed development of the the program for its lack of an adequate baseline, poor quality
Eagle Point orebody. Results of test mining since 1991 indi- control/quality assurance and improper selection of sampling
cate that the proposed mining methods are feasible and have sites. The panel concludes that, although the monitoring pro-
the potential to mitigate adverse environmental effects. The gram meets the requirements of the regulatory agencies for
Rabbit Lake tailings pit is the most appropriate option for compliance monitoring, it is not contributing to an overall un-
disposal of tailings produced by milling Eagle Point ore. Viable derstanding of the effects of the operation on the environment.
decommissioning plans for the Eagle Point mine and waste Moreover, the monitoring program has not assured the public
rock have been presented. However, a more comprehensive and northern communities that the project has not and will not
approach to data collection and analysis is necessary to ad- cause ecological damage. The panel has made recommenda-
dress the long-term concerns related primarily to tailings man- tions for development of an ecosystems-based monitoring
agement and decommissioning. Requirements for specific program in "Environmental Issues" (Section 4).
8 Overall Project Findings, Conclusions and Major Recommendations

Socioeconomic Issues The panel concludes that there is insufficient information to

reach an informed decision on the environmental effects of
Cameco is committed to the employment of northern and mining the A-zone and D-zone orebodies.
aboriginal people from the remote communities of northern
Saskatchewan. In 1992, 44% of the proponent's labour force 2. The panel recommends that mining of the A-zone and
consisted of northerners, with 40% being of aboriginal ances- D-zone orebodies not proceed until information on
try. Cameco made a commitment to increase the percentage waste-rock management and decommissioning is ob-
of northerners in its workforce to 50% by 1995. There are tained and until Cameco has demonstrated that both
recognizable benefits to northern communities as a result of short- and long-term adverse environmental impacts
this high proportion of northern employees; however, are mitigable.
Athabasca communities expressed the view that they should
receive a greater share of the benefits. The panel suggests
that Cameco should make every reasonable effort to achieve Public Involvement
the 50%-northern goal and should consider other initiatives
such as joint ventures to augment economic benefits to Whereas the panel has made recommendations regarding
Athabasca Basin communities. Cameco has made a consid- mining of the Eagle Point, A-zone and D-zone orebodies, it
erable effort to provide on-the-job training, which will develop recognizes that many aspects of these developments cannot
skills that can be transferred to other jobs within the operation be definitely or completely resolved through the panel review
or to other working situations. Educational initiatives have process. Aspects such as waste-management options,
also been undertaken which have been and will continue to be decommissioning strategies and monitoring requirements
of benefit. The panel concludes that overall the socioeco- evolve over the course of the operation. As data are gathered
nomic effects of this proposal are positive and that negative and operational proposals made, the regulators evaluate this
impacts are mitigable. information and implement their decisions through a staged
licensing process. Resolution of these issues requires a
longer timeframe than is available to the panel.
Health and Safety Issues
Primary responsibility for the regulation of uranium mining in
The panel recognizes that the perception of risk to the envi- Saskatchewan rests federally with the AECB and provincially
ronment is an important issue particularly for northern people with Saskatchewan Environment and Resource Management.
who are closest to the mine. The concerns include damage to A focus of the regulatory process is a Joint Review Group
the land, contamination of the aquatic environment and loss of composed of these agencies and Environment Canada. This
opportunities to harvest fish and wildlife. The panel concludes group provides a mechanism for coordinated government re-
that this perception may be changed by community input to view of the Rabbit Lake operation and determination of licens-
monitoring of the operation and by the use of traditional eco- ing requirements.
logical knowledge in the monitoring programs.

Cameco is dedicated to mine safety and radiation protection The panel heard that the public is concerned about what it
and has demonstrated that workers' levels of radiation expo- perceives to be the closed nature of the regulatory process.
sure would be below the accepted limits. On the basis of There seemingly is little opportunity for public input or for the
information provided by both the proponent and by govern- public to be informed in a timely manner of results of monitor-
ment agencies, the panel is satisfied that the radiological im- ing programs, operational changes proposed by the propo-
pact of the proposed development on the surrounding nent or licensing decisions. Other concerns were raised about
communities would be acceptable. the quality of baseline data and the scope of the environmen-
tal monitoring program. It is clear to the panel that changes to
the present regulatory decision-making process for the Rabbit
Lake operation are warranted to address deficiencies regard-
Overall Conclusions and Major ing both public involvement arid data quality.
Recommendations
The following overall recommendations must be viewed along The panel concludes that participation of the public, in particu-
with the panel's specific recommendations related to project lar the Athabasca Basin communities, in the decision-making
engineering, environmental, socioeconomic, health and process for the Rabbit Lake operation is essential to improv-
safety, and monitoring, enforcement and compliance issues. ing public trust in the regulatory regime. At the same time, the
panel acknowledges that the regulatory agencies have a legal
responsibility for the management of uranium mining and in
Based on the documentation provided to the panel and the
no way wishes to diminish or compromise this responsibility.
information gathered throughout the public hearings, the
panel concludes that full-production development of the un-
derground mine at Eagle Point could proceed without signifi- The question then is how to provide for public input in the
cant environmental, socioeconomic, health and safety effects. decision-making process while recognizing the legal responsi-
bilities of the regulatory agencies. The structure of the existing
1. The panel recommends that full-production under- Joint Review Group should be considered as the starting point
ground mining at Eagle Point be allowed to proceed in developing an improved decision-making framework. The
under the conditions described within the report. purpose of modifying the process is to improve the quality of
 Overall Project Findings, Conclusions and Major Recommendations 9

information available to those agencies responsible for regu- these areas is identified in "Project Engineering Issues" (Sec-
lating the industry and to make the regulatory process more tion 3) and "Environmental Issues (Section 4). A key responsi-
responsive to public concerns. bility of this committee would be to ensure that the information
collected on the Rabbit Lake site is of high quality and that this
3. The panel recommends that the Joint Review Group be information is efficiently and effectively communicated to the
restructured and expanded to create an Environmental public.
Management Committee for the Rabbit Lake operation.
The panel recommends that the AECB consult directly The panel recommends that meetings of the Environmental
with stakeholders to establish the nature of their repre- Management Committee be open to the public and that min-
sentation. Further, non-governmental participants utes of meetings be publicly available and distributed to inter-
should be compensated for their time and out-of- ested parties. The panel also suggests that the Environmental
pocket expenses. The panel suggests that funds col- Management Committee consider producing an annual report
lected by government from the industry be used to documenting the status of important activities at the Rabbit
finance these expenses. Lake site and its recommendations regarding these activities.
This report should be written so that it can be understood by
The panel has recommended that the stakeholders, in consul- the public, with summaries translated into Dene and Cree.
tation with the AECB, should ultimately determine the mem- The panel suggests that the committee should periodically
bership and structure of the Environmental Management evaluate its performance to ensure that it is fulfilling its man-
Committee. The parties may find it advantageous to use a date and is an effective tool for providing public input to the
neutral third party to help establish the process and to facili- regulatory process.
tate the selection of participants for the Environmental Man-
agement Committee. The panel concludes that in order for the Government funding to support the participation of the public,
committee to be effective, the following should be considered particularly northern communities, has been recommended. In
for membership: addition to compensation for out-of-pocket expenses and
time, the panel proposes funding of independent experts to
• present members of the Joint Review Group; advise the committee on specific issues. The panel is aware
that funds are scarce and wants to ensure that the committee
• Athabasca Basin communities, including Wollaston Lake;
does not strain limited resources. The committee may, in fact,
• informed environmental interest groups, for example, the help save money by reducing duplication in the regulatory
Saskatchewan Environmental Society; process. Further, a critical examination of the monitoring pro-
gram could identify areas where savings are possible. Finally,
• the scientific community; and if the committee is effective, it should eliminate the need for
further public reviews, which are costly in both time and
• other federal departments, for example, Fisheries and dollars.
Oceans and Health.
The panel concludes that providing representation for re-
The panel considers it important that aboriginal elders and sidents of the Athabasca Basin on the Environmental Man-
women be represented either directly or indirectly on the com- agement Committee will not be sufficient to address their
mittee. The panel proposes that Cameco attend many but fundamental concerns about the effects of the proposal on the
perhaps not all of the Environmental Management Committee environment. These communities have clearly stated that they
meetings to inform the committee of activities at the Rabbit want much more direct involvement, particularly in the moni-
Lake site and to discuss proposed operational changes. toring program. Ultimately, this involvement could include col-
lection and analysis of environmental and socioeconomic
The mandate of the Environmental Management Committee data.
would be to provide timely and relevant advice on key engi-
neering and biophysical issues related to the Rabbit Lake 4. The panel recommends that the Environmental Man-
operation; to ensure high standards of scientific analysis; to agement Committee and the proponent determine and
provide a forum for identifying and addressing public con- implement mechanisms for greater community in-
cerns; and to communicate information on these issues di- volvement in the monitoring program.
rectly to the stakeholders. The committee may also wish to
examine the nature of the regulatory process and explore The panel notes that the Department of Fisheries and Oceans
ways to reduce duplication. The committee's role would be has involved northern residents in monitoring programs. This
similar to that of the existing Joint Review Group; however, experience will assist in the development of similar programs
the committee would consider the broader concerns of the in the Athabasca Basin. The panel also encourages the pro-
public and other government agencies in a more integrated ponent to pursue proposals, such as heard from the Environ-
and coordinated fashion. mental Monitors of the Athabasca Region, to develop
community-based monitoring programs.
To provide advice on engineering and biophysical issues per-
taining to the Rabbit Lake site, the committee should specifi- Finally, the panel realizes that effective participation of north-
cally address baseline conditions, monitoring, waste-rock ern communities in monitoring programs and on the Environ-
management, tailings management, decommissioning and mental Management Committee requires education and
post-decommissioning strategies, water use, cumulative im- training. The panel suggests that schools in the community
pacts, and research needs. Specific information needed in could work with the proponent and the regulatory agencies to
10 Overall Project Findings, Conclusions and Major Recommendations

develop educational programs. The Environmental Manage- 5. The panel recommends that the AECB and other ap-
ment Committee may wish to investigate, with provincial and propriate agencies make their services available to the
local authorities, ways to integrate the activities at the Rabbit communities to assist in the development and imple-
Lake site into the curricula of community schools. The goal mentation of education and training programs.
would be to develop individuals in northern communities with
the skills and education necessary to actively participate in the
monitoring of the Rabbit Lake operation.
 Project Engineering Issues 11

3 PROJECT ENGINEERING ISSUES

During the review, there was considerable focus on the engi- During the hearings, Cameco confirmed that 0.03% uranium
neering aspects of the Rabbit Lake operation. A primary rea- oxide would be the cut-off grade for uranium in waste rock at
son for this focus was that project design and operation will the Rabbit Lake operation. The waste rock would be placed
determine the nature and scope of the effects on the environ- on the existing B-zone waste-rock pile, and the special waste
ment. Although many aspects of the operation were consid- would be placed in the bottom of the mined-out A-zone and
ered, five areas were of particular concern: waste-rock D-zone pits. The special waste would be covered with over-
management, tailings management, decommissioning, water burden, and water would be pumped into the pits. Depending
use and safety of the Eagle Point mine. on the resultant water quality in the pits, the dykes isolating
them from Collins Bay might eventually be breached.
One issue that relates to all aspects of project engineering is
the regulatory approach taken by the AECB, which is respon- A number of presenters commented on the proposed options
sible federally for the administration of uranium mining and for waste-rock management. Many expressed concern about
processing. The AECB's approach is to prescribe radiation adding to the B-zone waste-rock pile, since it is already a
dose limits that must not be exceeded and to require that the potential source of surface and groundwater contamination.
licensee develop its operation in such a manner that the Environment Canada proposed that all special waste be iso-
doses are As Low As Reasonably Achievable (ALARA). This lated in the underground workings at Eagle Point. Further,
ALARA principle ensures that operators do more than just Environment Canada officials suggested that the A-zone and
meet regulatory standards. During the hearings, several D-zone pits should be completely filled with waste rock, since
presenters proposed that the ALARA principle should apply it is their opinion that it will not be feasible to obtain satisfac-
not only to radiation dose but to all aspects of the operation. In tory water quality in the flooded pits.
response, Cameco indicated that, in fact, it follows the ALARA
principle in all aspects of project design and operation. The The proponent and the regulators agreed that the lack of
panel supports this approach. In the following sections, the information on the character of waste rock from the A-zone
panel makes a number of specific recommendations regard- and D-zone made it difficult to evaluate the short- and long-
ing the application of ALARA to additional development at term impacts of various waste management options. To pro-
Rabbit Lake. vide this information, Cameco proposed the following five-step
program.

3.1 Waste-rock Management Step 1: Review existing drill logs from the A-zone and D-zone
to establish requirements for drill-hole locations and
Most of the waste rock (91%) from the Eagle Point mine would depths.
be placed back underground. The waste would be cemented
and used to back-fill the stopes. Following mining, an esti- Step 2: Conduct a drilling program in the A-zone and D-zone
mated 150,000 m3 (broken) of waste rock would be left on the areas; log and sample the drill cores.
surface at Eagle Point. The proponent's preferred option is to
regrade and vegetate this rock since it is predicted to have low Step 3: Analyze the drill-core samples to determine acid-gen-
levels of contaminants. erating and metal-leaching potential.

It is estimated that mining of the A-zone and D-zone orebo- Step 4: Computer model various disposal and decommission-
dies would produce 376,000 and 589,000 m3 (broken) of ing scenarios to determine the environmental impacts
waste rock, respectively. Geochemical testing of the waste associated with each waste-rock management option.
rock has not been done, but experience with the B-zone pit
suggests it is likely to contain significant amounts of nickel Step 5: Prepare a report on the proposed waste-rock man-
and arsenic. agement plan for review by government agencies.

Cameco has proposed several options for disposal of waste Cameco estimated that the above program will be completed
rock from the A-zone and D-zone mines. These options in- in early 1995. The AECB advised the panel that this approach
volve classifying the waste rock according to levels of arsenic, was acceptable and that it should enable the proponent to
nickel, sulphur and uranium oxide (U3Oa) and separating out assess the impacts of managing wastes and decommission-
special waste for specific treatment. In order to develop a ing the two pits.
waste-rock classification system, studies to characterize the
rock are required. These studies have not been conducted; Several presenters told the panel that a complete understand-
however, for modelling and impact prediction, Cameco pro- ing of the geology and hydrogeology of the site is lacking. This
posed the following interim classification scheme. information is necessary to accurately model and predict con-
taminant movement and natural retardation in the subsurface
CONTAMINANT WASTE ROCK (%) SPECIAL WASTE (%) system. It was pointed out that waste rock left on the surface
Arsenic <0.02 >0.02 following mining of the original Rabbit Lake pit has not been
Nickel £0.02 >0.02 studied in detail, although the proponent did indicate that it
Sulphur <0.20 >0.20 would address this as part of an overall decommissioning
Uranium oxide <0.03 50.03 to <0.14 plan. The panel suggests that since this waste rock has been
12 Project Engineering Issues

exposed for a number of years, it provides an excellent oppor- 3.2 Tailings Management
tunity to examine contaminant movement. The results from
such investigations could then be used to improve the quality
Tailings produced from milling Eagle Point ore and, if ap-
of the modelling of waste-rock disposal options for the A-zone
proved, A-zone and D-zone ore would be placed in the Rabbit
and D-zone.
Lake tailings pit. The tailings, which consist of finely-ground
rock and chemical precipitates from the milling process, will
The panel has concluded that there is insufficient information contain minor amounts of radionuclides, including uranium,
to reach a recommendation with regards to mining of the radium and polonium, and unleached portions of other metals.
A-zone and D-zone orebodies. The panel therefore urges The Rabbit Lake tailings disposal system has an innovative
Cameco to undertake and complete the waste-rock testing "pervious surround" design. The objective of this design is to
and analysis program that it outlined to the panel. Cameco produce a consolidated, highly impermeable mass of tailings
should include in the testing program a comprehensive evalu- within a highly permeable envelope. After the tailings pit is
ation of the surrounding soils, geology and hydrogeology to decommissioned, groundwater is predicted to follow the path
obtain the information necessary to accurately predict con- of least resistance and flow around, rather than through, the
taminant movement. Further, the panel suggests that Cameco tailings. The tailings pit is licensed by the federal and provin-
consider a broad range of waste-rock management options, cial governments and has been in operation since 1985. A
including disposal of special waste in the underground work- total of approximately 2,700,000 tonnes of tailings had been
ings of Eagle Point. deposited in the pit by the end of 1992.
6. The panel recommends that Cameco develop a
waste-rock management plan for the A-zone and Before tailings were placed in the mined-out Rabbit Lake pit, a
D-zone orebodies and that mining of these orebo- pervious envelope was prepared by placing a layer of crushed
dies not proceed until the plan has been reviewed rock on the bottom and side walls of the pit. A layer of sand
and approved. The plan should include the follow- placed inside the crushed rock acts as a filter to prevent the
ing essential elements: tailings from entering and thus clogging the pervious layer.
Tailings were initially placed in the pit in the form of a filter
a) a waste-rock classification scheme that can be cake. Subsequently, tailings were in the form of a slurry con-
justified on the basis of environmental protec- taining approximately 40% solids. The pervious surround pro-
tion and on meeting the ALARA principle; vides a seepage path for pore water, thus promoting
consolidation of the tailings. The pore water is collected in a
b) confirmation that the proposed classification sump at the base of the pit and pumped back to the mill for
scheme will separate waste rock reliably from treatment.
special waste and ore;
When milling is completed and all tailings have been placed in
c) impact predictions that fully consider the con- the pit, the excess pore water will be removed, leaving a
ditions in the natural environment that will re- consolidated mass of tailings with low permeability. Pumping
ceive the waste; and will then cease, and the natural water table will be allowed to
reestablish itself. Elimination of the pore water should remove
d) monitoring requirements to determine if the
the driving force that could expel contaminants from the tail-
predictions are correct, to identify impacts not
ings. After decommissioning, molecular diffusion is predicted
predicted and to provide data for the develop-
to be the only remaining contaminant-release mechanism.
ment of decommissioning plans.
The rate of diffusion is anticipated to be slow enough that
surrounding water quality would not be affected.
It is the panel's view that the Environmental Management
Committee should take an active role in the review of the
waste management plan and that the committee would pro- Since the tailings will contain radioactive materials and heavy
vide the mechanism for public input to the review. To fully metals, considerable concern was expressed at the hearings
evaluate the waste-rock management plan proposed by about the ability of the tailings facility to contain these materi-
Cameco, the committee will need a set of criteria. These als over the long term. The panel was advised that the pervi-
criteria could include: water quality objectives if the pits are to ous surround method was the most appropriate technology for
be flooded; site-specific water quality criteria for Collins Bay; containing tailings and had a number of advantages over sur-
and performance standards for waste-rock sorting. face tailings disposal. However, the pervious surround
method is relatively new and considered by some presenters
7. The panel recommends that the Environmental to be experimental. Further, a pervious surround tailings man-
Management Committee develop criteria to evaluate agement system has never been decommissioned; hence,
the proposed waste-rock management plan. predictions on the long-term containment abilities of the pit are
based solely on modelling.
Given that the waste-rock management scheme will not be
presented until early 1995, the committee has adequate time The level of uncertainty in the predictions could be reduced if
to develop the evaluation criteria. In fact, it would be desirable the models were calibrated with site-specific measurements of
if the committee were to develop such criteria and provide the physical environment and validated based on perform-
them to Cameco before its testing and analysis program were ance of the tailings pit to date. The results of the monitoring
completed. programs have allowed some validation of the modelling.
 Project Engineering Issues 13

Cameco reported that consolidation of the tailings has oc- does not give an accurate measure of pore-water quality since
curred more rapidly than predicted. This supports the view it is a mixture of pore water, groundwater and surface runoff.
that knowledge of the system's functioning is incomplete
or that the models require revisions, or both. The panel was 8. The panel recommends that Cameco implement a
told that the contaminant migration models had not been comprehensive monitoring and assessment pro-
calibrated with site-specific conditions. In response, the gram for the Rabbit Lake tailings pit. As part of this
proponent indicated that there were opportunities on program, Cameco should undertake the following
the site to calibrate and validate the models prior to site tasks.
decommissioning.
a) Assess whether the properties of the tailings
are consistent with those used when the facility
Two specific issues that could affect the operation of the tail- was designed.
ings disposal facility were raised. There is some evidence that
ice lenses have formed within the tailings. If these areas of ice b) Calibrate and update predictive models on con-
remain following decommissioning, they could have a detri- taminant transport in the receiving environment
mental effect on surrounding water quality since they could using data from field testing of the B-zone tail-
thaw and expel contaminated pore water. Cameco advised ings, Rabbit Lake tailings, Rabbit Lake waste
the panel that several techniques could reduce this problem; rock and B-zone waste rock.
for example, providing additional snow or water cover to insu-
late the tailings and thereby reduce freezing, or subaqueous c) Determine the appropriate tailings' properties,
deposition of the tailings in the centre of the facility. Another including permeability and porosity, by field
issue that could affect the functioning of the system is segre- testing.
gation of the tailings. If the tailings are discharged over a large
area, the coarser fractions settle out in the upstream portion d) Determine the permeability and relevant hy-
and the finer particles settle out in the downstream portion of draulic properties of all surrounding rock units
the tailings pit. The result is that permeabilities are relatively by field testing.
high in upstream portions and low in the downstream area.
Areas of low permeability would retain pore water longer, e) Define the quality of pore water in order to esti-
which might result in areas of frozen tailings. Tests at Rabbit mate the quality of water that may reach the
Lake indicate that segregation of tailings is occurring. Cameco receiving environment.
indicated that it can manage this problem by maintaining a f) If the water cover option were to be selected for
relatively high solids content in the slurry, keeping the tailings decommissioning the pit, predict the long-term
beach short, and periodically rotating the discharge points. quality of surface water and surrounding
groundwater using three-dimensional flow or
The panel concludes that the Rabbit Lake tailings pit ap- geochemical models.
pears to be the most appropriate tailings disposal option.
Information presented to the panel indicates that the pit g) Maintain a detailed inventory of the chemical
seems to be functioning largely as predicted. However, and physical characteristics of tailings depos-
since the pit represents a new and untested approach to ited in the facility.
tailings management, a detailed monitoring program is
The panel has recommended that the Environmental Manage-
essential to calibrate the models, to verify model predic-
ment Committee play a key role in the development and im-
tions, and to identify conditions not predicted so that
plementation of the Rabbit Lake tailings pit monitoring and
they can be addressed. This program could be conducted
assessment program. Further, the committee should review
in parallel with mining at Eagle Point.
results of this program and, if necessary, recommend
changes in tailings management to ensure that the pit is not
Cameco informed the panel that the current monitoring pro- causing significant adverse environmental impacts.
gram for the tailings pit includes quality control of the pervious
envelope materials; measures tailings settlement and pore-
water pressure; samples tailings to determine their properties; 3.3 Decommissioning
samples and analyzes water pumped from the pit; and sam-
ples and analyzes the surrounding groundwater. During the The panel's mandate includes an examination of impacts of
hearings, concerns were expressed that some aspects of the the proposed development during the decommissioning and
monitoring program were not being implemented quickly post-decommissioning phases. It is difficult to address this
enough, that the public had difficulty obtaining results from the aspect in detail at this time, since decommissioning proposals
monitoring program, that modelling has not been sufficiently are largely conceptual. A number of issues raised during the
validated with field measurements, and that a comprehensive review need to be considered before decommissioning plans
program to define the surrounding geology, hydrology and can be finalized. The proponent indicated that it needs more
geochemistry is lacking. Specific concerns were that models data and modelling before it can develop final decommission-
are based on laboratory rather than field measurements of ing plans. The panel concludes that involvement of the Envi-
tailings permeability; the surrounding rock is assumed to be a ronmental Management Committee in the development of
homogeneous mass, whereas several geologic strata are decommissioning plans is essential to ensure that public con-
known to exist; and sampling of water pumped from the pit cerns about this phase of the operation are fully addressed.
14 Project Engineering Issues

Eagle Point Another issue related to waste rock is the possibility of acid
generation. Oxidation of sulphides in exposed ore can result
An estimated 1 million tonnes of waste rock would be left on in the generation of acid, which leaches radionuclides and
the surface following mining of the Eagle Point orebody. heavy metals from the rock. The proponent's consultant on
Cameco indicated that it plans to undertake a waste-rock this matter advised the panel that waste rock would be classi-
characterization program and model potential impacts. If mod- fied according to acid-generation potential and that oxidation
elling indicates that the waste rock would result in significant of sulphide-rich rock would be controlled either by keeping the
contamination, then capping options to reduce infiltration and rock under water or by covering it.
prevent leachate generation would be considered. Following
completion of mining, surface facilities would be removed and A number of alternative proposals for decommissioning the
contaminated materials would be placed in appropriate facili- B-zone waste-rock pile were presented. Environment Canada
ties. All raises would be sealed with reinforced concrete. proposed that Cameco reduce the size of the waste-rock pile
by using the rock to cap tailings and special waste and to fill
The panel concludes that an adequate conceptual decom- open pits that would be otherwise flooded. Further, it recom-
missioning plan for the Eagle Point mine has been pro- mended the use of extensive groundwater and hydrological
vided; however, this plan needs to be integrated into a contaminant modelling to determine the most appropriate
comprehensive decommissioning plan for the Rabbit cover option for the B-zone waste-rock pile. The Saskatche-
Lake site. wan Environmental Society proposed two options for the
B-zone waste-rock pile. One option is to place as much of the
waste rock as possible in the Rabbit Lake tailings pit and
A-zone and D-zone provide a complex cover for the remainder of the rock. The
other option is to leave the waste-rock pile intact and provide
Cameco's preferred option for decommissioning the A-zone a complex cover. The complex cover proposed by the Sas-
and D-zone pits is to follow the same strategy as for decom- katchewan Environmental Society would consist of several
missioning the B-zone pit: i.e., place special waste in the layers designed to reduce erosion and prevent infiltration. The
bottom of the mined-out pit and cover it, pump water into the AECB made it clear that approval for final decommissioning or
pit, and, once adequate water quality develops in the pit, abandonment of the B-zone pit area, including the waste-rock
breach the dykes that isolate it from Collins Bay. The B-zone pile, had not been given.
pit has been flooded for about one year. Preliminary monitor-
ing results indicate that levels of nickel, arsenic and radium The panel concludes that there is insufficient information
are elevated, although this may be related to high levels of to determine whether the A-zone and D-zone pits and
suspended solids. Modelling results presented by the propo- waste rock generated from these pits can be successfully
nent suggest that levels of arsenic, nickel and uranium in the decommissioned. The information required would come
B-zone pit will exceed Saskatchawan Surface Water Quality from analysis of waste-rock management options, experi-
Objectives both in the short and long term. This information ence in decommissioning the B-zone pit and from de-
was used by the Saskatchewan Environmental Society to tailed modelling.
support its position that mining of the A-zone and D-zone
orebodies is unacceptable; by Environment Canada, to sug- 9. The panel recommends that mining of A-zone and
gest that the pits be filled with waste rock; and by Fishories D-zone not proceed until the proponent has demon-
and Oceans, to recommend that the dykes between the pits strated that the B-zone pit and waste-rock pile can
and Collins Bay not be breached. In response, Cameco indi- be decommissioned without significant adverse en-
cated that there are a number of options to improve the water vironmental impacts and that detailed plans for
quality of the pit if monitoring continues to indicate that the decommissioning of A-zone and D-zone pits and
quality is unacceptable. These options include adding a floc- waste rock have been prepared and approved. The
culant to settle the suspended solids; spraying the pit with proponent should demonstrate that these plans
ferric sulphate to reduce arsenic concentrations; and promot- meet the ALARA principle.
ing the growth of algae that are known to remove contami-
nants. The AECB advised the panel that it still had major
concerns about the decommissioning of the proposed A-zone Rabbit Lake Tailings Pit
and D-zone mines.
Cameco's proposal for closure of the Rabbit Lake tailings pit
Modelling results provided by the proponent indicate that the is to place 1.5 m of sand on top of the tailings. After placement
B-zone waste-rock pile is a potential source of contamination of the cover, groundwater levels would be allowed to return to
of the B-zone pit. This aspect of the development is of interest normal, and Rabbit Lake would be restored. Predictions of
to the panel since Cameco proposes to place waste rock from water quality in the restored Rabbit Lake have been made,
the A-zone and D-zone on the B-zone waste-rock pile, which although these do not consider the contribution of Rabbit Lake
would increase the size of the pile by 17%. Cameco's pre- waste rock placed near the pit. Environment Canada stated
ferred decommissioning plan for the B-zone waste-rock pile is that further assessment of cover options is required and advo-
to grade and vegetate it; however, Cameco indicated that, if cated the use of a waste-rock cover. The AECB advised the
modelling predicted an unacceptable impact on water quality panel that the information presented on the Rabbit Lake tail-
of the B-zone pit, it would examine cover options to reduce ings disposal facility was adequate to fulfil its requirements for
infiltration and leachate generation. a conceptual decommissioning plan.
 Project Engineering Issues 15

The panel concludes that viable options for decommis- Depending on the phase of the operation and the season,
sioning of the Rabbit Lake pit have been proposed. Col- significant quantities of water requiring treatment would come
lection of additional information on the pit and detailed from the Eagle Point mine and, if approved, A-zone and
modelling would be required for the development of a D-zone pits, Rabbit Lake tailings pit, Rabbit Lake mill and
final decommissioning plan. surface runoff. In addition, the mill would require between 13.5
and 24.4 litres/sec. (L/s) of freshwater from Collins Bay.
Comprehensive Decommissioning Plan In response to a question from the panel, Cameco identified
four opportunities to reduce water usage in the mill and,
The foregoing discussion has addressed a number of specific
hence, discharge to the environment.
issues related to decommissioning of the Eagle Point, A-zone
and D-zone mines, the B-zone waste-rock pile, and the Rabbit 1. Add a clarifier to the mill effluent-treatment circuit to
Lake tailings pit. Since these components are located on the produce water of suitable quality for seal water and
Harrison Peninsula, which is surrounded by Wollaston Lake, other mill make-up uses.
any environmental effects resulting from decommissioning of
the Rabbit Lake project could affect adjacent areas of the 2. Aerate water pumped from the tailings pit to reduce
lake, including Collins Bay, Ivison Bay and Pow Bay. The radon, thus making the water suitable for use in the mill
proponent presented modelling results to indicate that these as seal water.
impacts would be minimal. However, the panel was advised
3. Replace wood-stave tanks to eliminate the need to
that the models used to predict contaminant generation and
spray them with water.
movement were based, to a large extent, on assumed values
and that these models had not been validated by field mea- 4. Use boiler condensate for seal water.
surements. Ultimately, the panel concludes, an overall com-
prehensive site decommissioning plan would be required. Cameco also indicated that in the spring a large amount of
snow melt and runoff is collected from secondary containment
10. The panel recommends that Cameco initiate the facilities around pipelines and ore pads. All this water is
studies required to develop a comprehensive treated before it is released to the environment, even though
decommissioning plan. In the panel's view, some of contaminant levels are likely low. Cameco is examining ways
the essential elements in this plan are the following: to minimize the amount of surface water being collected and
treated while maintaining the integrity of the secondary con-
a) the evaluation of existing water-quality stan- tainment system.
dards to determine whether these represent ad-
equate targets for decommissioning or whether Environment Canada made a number of recommendations to
site-specific standards are required; reduce the volume of contaminated water produced. It sug-
gested that Cameco investigate the use of dewatering wells to
b) the development and validation of models to
reduce groundwater inflows to the Eagle Point mine. Further,
evaluate the environmental effects of various
it proposed that uncontaminated groundwater flows to the
decommissioning options and the development
Rabbit Lake tailings pit be collected separately, thus reducing
of a decommissioning strategy that meets es-
the amount of water pumped from the pit. In addition, it identi-
tablished targets;
fied a number of possible improvements to the treatment sys-
c) the establishment of baseline conditions and tem that could reduce contaminant loading.
determination of the nature and extent of a 11. The panel recommends that Cameco investigate
post-decommissioning monitoring program means to reduce the amount of water that requires
that will be used to evaluate the environmental treatment and the amount of freshwater used.
effects of decommissioning activities; and These reductions would decrease contaminant
d) an estimate of the time frame and financial re- loading to Hidden Bay and thus achieve the goal of
sources required to complete the decommis- the ALARA principle with respect to potential im-
sioning program. pacts on the biophysical environment. Investigation
of water use at the Rabbit Lake operation should
The panel has recommended that the Environment Manage- include the following:
ment Committee play an active role in the review and ap- a) the consideration of improved milling and
proval of a comprehensive decommissioning plan for the water-treatment processes that would result in
Rabbit Lake site. lower contaminant loadings;
b) an investigation of ways to use uncontaminated
3.4 Water Use mine-site runoff and mine water in the mill to
reduce freshwater consumption;
On several occasions during the review process, the panel
asked the proponent to provide information on water use at c) the reassessment of groundwater inflows to the
the Rabbit Lake operation. The purpose of this question was Eagle Point mine and, if approved, A-zone and
to obtain a clear understanding of water volumes and contam- D-zone mines to identify options for further re-
inant loads from various aspects of the operation, since these ducing volumes of contaminated mine waters;
ultimately affect contaminant loading to Hidden Bay. and
16 Project Engineering Issues

d) the examination of alternative methods of plac- detect any movement of the rock mass. In addition, the crown
ing tailings in the pit and operation of the facil- pillar is typically checked at the beginning of and during each
ity to reduce the amount of contaminated water shift.
pumped from the facility.
Cameco's Addendum addressed the potential impact on Wol-
3.5 Safety of Eagle Point Mine laston Lake of flooding the Eagle Point mine. Cameco indi-
cated that once the mine was flooded there would be very little
A number of participants expressed concerns about the safety driving force to cause an exchange of water with Collins Bay,
of mining under Wollaston Lake. Northern communities in par- and that the volume of the underground mine in relation to the
ticular were concerned that if the mine were to collapse and total volume of Wollaston Lake would be very low, further
become flooded it would be a significant source of contamina- reducing the potential for contamination.
tion to the lake.

The panel received a presentation from the proponent's rock The panel concludes that the risks of a collapse of the
mechanics consultant and additional information in Cameco's Eagle Point mine, and potential contamination of Wollas-
Addendum. The mine is designed with a 50-m thick undis- ton Lake, are minimal and that an adequate program to
turbed rock mass, termed a crown pillar, between the top of manage these risks is in place.
the mine and the lake. Mining will not be permitted in the
crown pillar. The size of the pillar has been based on ge- 12. The panel recommends that results of the crown-
otechnical models and experience with other mines located pillar monitoring program and any significant
under water bodies. The panel was also advised that a num- changes in the design of the pillar be provided to
ber of instruments had been installed in the crown pillar to the Environmental Management Committee.
 Environmental Issues 17

4 ENVIRONMENTAL ISSUES
The effect of the proposed development at Rabbit Lake on the effects, the current monitoring program appears to provide
biophysical environment is a significant issue in this review. little assurance to those who could be most directly affected
Contamination of the environment by radionuclides and heavy by the project. Although the monitoring program may have
metals is of primary concern. Effluent discharged into Hidden met the requirements of regulatory agencies, it is clear that
Bay is the most obvious source of contamination; however, the program has neither satisfied public concerns nor gained
other potential contaminant sources include the A-zone and public trust.
D-zone pits, waste-rock piles, and the Rabbit Lake tailings pit.
Contaminants from these sources could find their way into the The quality of the monitoring data is of particular concern.
surrounding aquatic environment, including Collins Bay, Pow Based on the data presented to the panel, there appears to be
Bay and ivison Bay (Figure 2). a lack of quality control in at least some aspects of the moni-
toring program. For instance, analytical procedures for ra-
Based on current and predicted performance of the operation, dionuclides and trace elements in fish tissues were changed
the panel concludes that impacts of full-production mining at in 1982, 1984 and 1986, and the data from 1989 and 1990
Eagle Point on the biophysical environment are either insignif- were discarded because of problems with the analyses. As a
icant or mitigable. However, a comprehensive baseline study result, there are few comparable data from a decade of sam-
and monitoring program is required to confirm that these pre- pling for a factor of utmost importance to northern residents
dictions are correct. The panel has concluded that there is who consume fish from Wollaston Lake. Another example of
insufficient information to assess the environmental impacts of lack of rigor in monitoring is the fact that many of the vegeta-
developing the A-zone and D-zone orebodies. tion plots established in 1979 could not be found in 1986,
making comparison over a broad range of vegetation types
Monitoring is an essential component of the environmental almost impossible. The panel concludes that the collection
assessment process. Monitoring programs can determine if and analysis of biological samples did not meet professional
actual impacts are as predicted, ascertain whether mitigation standards. These examples inspire little confidence in the
programs are effective in reducing impacts, and identify im- ability of the company or the regulatory agencies to ade-
pacts not predicted so that they can be mitigated. Cameco quately manage a monitoring program.
used results of monitoring programs at Rabbit Lake to support
its position that the environmental effects of the proposed A key component of any monitoring program is a high quality
development would be minimal. For these reasons, monitor- baseline study. Baseline data should be of adequate quality to
ing programs were the focus of the discussion on environmen- serve as a basis for statistical and scientific comparison with
tal issues at the hearings. subsequent data sets taken during and after development of
the project. The goal is to draw fact-based, objective conclu-
sions about impacts based on well-defined and repeatable
4.1 Observations on the Monitoring Program methods. In addition, properly conducted baseline studies
provide the basis for impact prediction and development of
In its presentation to the panel, Cameco stated that it has mitigation programs. The panel concludes that the baseline
monitored the Rabbit Lake operation and the surrounding en- for the Rabbit Lake operation is inadequate.
vironment for the past two decades. In 1992, approximately
7,000 samples of air, water, lake sediments, plants and fish The quality of a monitoring program should be judged on the
were collected. The company estimates that approximately 23 basis of how well it provides answers to questions raised
person-years of effort and in excess of $2 million are dedi- during the design of the program. A monitoring program
cated annually to monitoring and surveillance programs. should be a real-world test to see if predictions were correct
and a means of early detection of unpredicted problems and
Cameco's claim that monitoring demonstrates that its Rabbit impacts. The monitoring program should also provide informa-
Lake operations have caused "very little impact on the local tion to demonstrate to the public that the impacts of the devel-
environment" was the subject of considerable discussion at opment are not significant. Based on these criteria, the
the hearings. This claim was generally supported in presenta- Rabbit Lake monitoring program must be judged as
tions made by the AECB. A number of presenters expressed inadequate.
the view that the industry is well regulated and they were
In summary, the panel concludes that the baseline data
confident that the environmental effects were minimal. How-
and monitoring program are deficient from both a scien-
ever, many other presenters expressed a lack of confidence in
tific and a public perspective. Poor quality can result from
the monitoring program and hence disputed the conclusion
either poor planning or poor workmanship. Better plan-
that impacts were minimal. Some raised specific issues re-
ning of baseline studies and monitoring programs and
lated to the design of the program. For example, the Sas-
the application of modern standards, concepts and tech-
katchewan Environmental Society questioned the location of
niques are necessary to improve the quality of the data.
sampling stations in Hidden Bay. Others had more general
concerns about the program that could be characterized as a
lack of confidence in the regulatory agencies. In the 4.2 Responsibility for Monitoring
Athabasca region, the lack of community involvement in the
monitoring program was often mentioned. Despite efforts by Requirements for monitoring are specified in licences issued
Cameco to inform northern residents about the project and its by the AECB and Saskatchewan Environment and Resource
18 Environmental Issues

Management. These requirements are reviewed annually at a Issues that should be considered during such a review include
meeting between the company and the regulatory Joint Re- the need for an ecological approach, baseline studies, a qual-
view Group. Changes to the monitoring program are made, as ity assurance/quality control program, environmental effects
appropriate, and are agreed to by all parties. Sampling is monitoring, pathways analyses, research programs and a
done largely by the company, although the regulatory agen- study of cumulative effects. Specific requirements are detailed
cies take spot samples to check the accuracy of the com- below.
pany's sampling and analysis program. The fact that most of
the sampling and analysis was done by the company was of The panel is of the opinion that most of the funding require-
concern to some presenters. The panel was told that monitor- ments for a revised monitoring program could be met by real-
ing programs are directed primarily at compliance with licence locating the 23 person-years and more than $2 million that
requirements, but they are also designed to consider effects Cameco spends annually. Further, the panel notes the propo-
on the environment. nent's comment that there is some duplication 'in federal and
provincial regulatory requirements which results in increased
A number of alternative ways to conduct the monitoring pro- costs to the company. Elimination of this duplication might
gram were presented. For example, the community of Wollas- provide an additional source of funds for monitoring.
ton Lake specifically requested that the company provide
funds for the community to establish its own monitoring pro-
gram. The Environmental Monitors of the Athabasca Region
4.3 Baseline Studies
proposed to establish a group that would monitor uranium A baseline study is a tool for making before and after compari-
mining development in the Athabasca region and provide re- sons to determine if development has caused changes in the
sults of the monitoring program directly to northern communi- environment. Baseline data ideally should be collected prior
ties. An independent citizens' environmental group, to construction of any project. It is not possible to provide a
composed of representatives from northern band councils and true baseline for the Rabbit Lake operation because mining
community-based organizations, environmental organizations has been conducted at the site for a number of years. It is,
and universities, was recommended by the Saskatchewan however, possible to provide a baseline for the mining of the
Environmental Society. This group would review monitoring Eagle Point, A-zone and D-zone orebodies.
results to determine whether licence conditions were being
met and would oversee the development and implementation, 14. The panel recommends that Cameco undertake a
of decommissioning plans. The AECB provided the panel with comprehensive baseline study that can be used to
examples of community monitoring committees in Ontario. monitor and assess the effects of additional devel-
The role of these committees is to review data on the receiv- opment at the Rabbit Lake site. The baseline study
ing environment and to inform the regulators about community should meet the requirements developed by the En-
opinions and concerns. The AECB indicated that it would be vironmental Management Committee.
willing to provide advice to stakeholders in northern Saskatch-
ewan interested in establishing a similar program. The panel has recommended that the Environmental Manage-
ment Committee be the forum in which baseline study require-
ments are developed. In developing an operational definition
In 1990, Cameco established the Northern Community Liai-
of a baseline for Rabbit Lake, the committee needs to specify
son Committee. This committee provides a forum for dialogue
in detail how and why samples will be collected and analyzed;
between the corporation and elected northern leaders on is-
indicate how data from the baseline will be used in the future
sues of concern, including environmental matters. The com-
to draw conclusions about impacts; and to justify and outline
pany also noted that one of the four environmental technicians
the details of sampling, statistical and other methods that will
at Rabbit Lake is a resident of the Athabasca region. While
be used to make pre- and post-development comparisons.
the panel supports these initiatives, it concludes that they do
not go far enough in providing assurance to northern commu- A comprehensive baseline study should consider the following
nities. The panel notes with interest the closing statement
elements.
from Cameco that "we agree that monitoring of the sites by
northern residents is one of the best ways to build trust and • The location of the baseline study areas should be ex-
confidence in the monitoring program and its results." amined. Clearly, the baseline study should focus on Hidden
Bay, since this is where the effluent from the operation is
The panel concludes that the public, particularly northern discharged. Hidden Bay also has the advantage of being
residents, wants a say in the design and implementation relatively small and, therefore, manageable from a sampling
of the monitoring program for the Rabbit Lake operation. and analysis perspective. Consideration should also be
The panel has previously recommended that establish- given to gathering baseline data on conditions in other bays
ment of an Environmental Management Committee is es- adjacent to the Rabbit Lake operation (e.g., Collins Bay,
sential to provide this input. Ivison Bay), and on the terrestrial environment.

13. The panel recommends that, to rectify the inadequa- • The baseline in Hidden Bay should ideally include all spe-
cies in the baseline and monitoring data, the Envi- cies of insects, crustaceans, molluscs, fish, plankton and
ronmental Management Committee undertake a plants. It could also include microinvertebrates and bacte-
complete review of the current monitoring program ria, since these are often active members of ecological sys-
and recommend changes to meet community, sci- tems and may be involved in the pathways of metals and
entific and regulatory requirements. radionuclides, especially in the sediments.
 Environmental Issues 19

• The need for surveys of rare species and evaluation of Another approach is to identify and monitor valued ecosys-
valued ecosystem components should be determined. tem components, i.e., attributes of the environment for which
there is a public or professional concern. Valued ecosystem
• Scientific quality control should be maintained by taking components can be determined on the basis of social, cul-
replicate samples, hiring only qualified taxonomists and field tural, economic, ecological or aesthetic values. In the case of
workers, and retaining voucher specimens and samples. this project, valued ecosystem components might include
Samples, data, and information on the methods used human food organisms (fish and caribou) and furbearers,
should be available to the public so that independent groups which are important to the aboriginal way of life. Although this
can undertake duplicate sampling or analysis if they so approach goes beyond compliance monitoring, in that biota
desire. rather than physical and chemical parameters are monitored,
it does not lead to a complete understanding of the system.
• The baseline study should consider an analysis of ecologi-
cal interrelationships, for example, population densities, A third approach, which stimulated considerable discussion at
food chains, species diversity, energy flow and nutrient the hearings, was that of pathways analysis. This approach
cycling. uses field studies and computer models to examine the move-
ment of contaminants through the food chain. Pathways anal-
• In addition to the biota, physical parameters, such as sea- yses were used by both the proponent and the AECB to
sonal cycles in the limnology of Hidden Bay, need to be demonstrate that the radiological impact of the additional de-
measured. The pH, oxygen profile, and thermal stratifica- velopment at Rabbit Lake would be acceptable. The panel
tion, as well as the physical conditions in the sediments was provided with information on field studies of lead and
where the benthos dwell, could be included in the baseline. polonium pathways in lichens, caribou and wolves that shows
the practicality and value of this approach. Environment Ca-
• Existing data on concentrations of heavy metals and ra- nada recommended that the proponent conduct radionuclide
dionuclides in biota, water and sediments should be re- pathway analyses for local aquatic and terrestrial food chains
viewed to determine if these are adequate. in addition to the analyses for regional food chains already
performed. The results of the pathway analyses could be used
• Reviews of the scientific literature on toxicity and bioac- to identify areas where environmental monitoring is required.
cumulation could be incorporated into information gathered
from the field work. The panel concludes that there is a need for compliance
monitoring to ensure that regulatory standards are being
met, for monitoring of valued ecosystem components to
4.4 Monitoring ensure that critical food items for local communities are
not contaminated, and for pathways analysis based on
The primary purpose of the baseline survey would be to pro- field data to provide a greater understanding of the fate of
vide an understanding of the structure and function of biota in heavy metals and contaminants discharged to the envi-
Hidden Bay and the components of the physical environment ronment. The panel believes that a well-planned and inte-
that affect these organisms. The baseline survey in Hidden grated monitoring program can achieve all these
Bay would identify key biotic and abiotic components that objectives. As previously recommended, the Environ-
should be incorporated into the revised monitoring program mental Management Committee is the appropriate forum
and in the baseline for other areas of the site. Selection of key to develop this program.
biotic components could be based on such factors as abun-
dance, function in the food chain, sensitivity to heavy metals 15. The panel recommends that Cameco implement a
and radionuclides, and use by humans. detailed monitoring program that meets the require-
ments developed by the Environmental Manage-
As noted above, the panel has recommended that the Envi- ment Committee.
ronmental Management Committee review the existing moni-
toring program and provide recommendations for change. In The panel proposes that the monitoring program initially focus
addition, the committee should consult with the scientific com- on Hidden Bay for the same reasons discussed in the section
munity and review the literature when determining monitoring on baseline studies. Depending on the results of the monitor-
requirements. During the public hearings, it became apparent ing program in Hidden Bay, the program may need to be
that the purpose and objective of a monitoring program were expanded to include other areas around the operation. The
viewed differently by a number of presenters. The main views monitoring program in conjunction with a baseline study
are outlined below. should:

The AECB indicated that compliance monitoring is required • determine how the Hidden Bay ecosystem functions and
to check that effluents from the mine do not exceed prescribed identify important parameters and interrelationships;
limits. This approach primarily involves monitoring physical
and chemical attributes of the effluent and the receiving envi- • identify the fate of contaminants discharged to the aquatic
ronment. While this is necessary from a regulatory viewpoint, environment and examine the effects of these discharges
it represents an incomplete view of the environment and on the aquatic biota;
neither considers factors such as total loading to the environ-
ment over the course of the development nor does it incorpo- • evaluate the effectiveness of current regulations and guide-
rate the concept of cumulative impacts. lines in protecting the aquatic environment;
20 Environmental Issues

• examine and determine the effects of loading on the aquatic presenters addressed the broader issue of the cumulative
environment; effects of the Rabbit Lake development and other uranium
mines proposed or operating in northern Saskatchewan. This
• determine the need for site-specific water quality criteria to broader issue is beyond the panel's mandate but is being
evaluate environmental impacts in Hidden Bay; and addressed by the Federal/Provincial Panel on Uranium Mining
Development in Northern Saskatchewan.
• determine the need for other site-specific or regional moni-
toring programs based on the results obtained from Hidden
Bay. Cameco discussed the cumulative effects of additional mining
at Rabbit Lake in its EIS Addendum. The proponent con-
cluded that during the operational phase the cumulative im-
4.5 Research Requirements pact of mining Eagle Point, A-zone and D-zone would be
minor. However, following decommissioning of A-zone and
The panel recognizes that there are a number of areas where D-zone and flooding of the pits, there may be an impact on
additional research is required to improve understanding of Collins Bay. Additional studies on the A-zone and D-zone
the effects of uranium mining and milling on the environment. proposal are required to address this issue.
A comprehensive monitoring program in Hidden Bay could
provide some of this information. Further, the monitoring pro-
gram might provide the platform on which government and The panel concludes that the cumulative effects of min-
universities could build other, more specific, research ing the Eagle Point orebody are likely to be either insig-
programs. nificant or mitigable, whereas those associated with
mining the A-zone and D-zone orebodies are unknown.
16. The panel recommends that the Environmental Comprehensive studies and monitoring programs are re-
Management Committee identify research needs quired to verify that these predictions are correct. Addi-
and establish communication with those (e.g., uni- tional information on the cumulative effects of mining at
versities, research institutes) that have the re- the Rabbit Lake operation will come from engineering
sources and abilities to conduct the research. studies associated with mine development and decom-
missioning and from environmental monitoring pro-
In general, research could be carried out on basic taxonomy, grams. It is important that these programs be coordinated
food webs and food chains, community and population struc- and their results assessed comprehensively to maximize
ture, interactions among the biotic community, radionuclides understanding of cumulative impacts.
and heavy metals, and the dynamics of the physical environ-
ment in relation to organisms and hazardous materials.
17. The panel recommends that the Environmental
Management Committee provide input into the de-
4.6 Cumulative Impacts sign of engineering and monitoring programs and
evaluate the results of these programs to identify
The Rabbit Lake panel was instructed to assess the cumula- any cumulative effects of additional development at
tive impacts of the existing operation and the proposed devel- Rabbit Lake and to recommend ways to address
opment of the Eagle Point, A-zone and D-zone mines. Many any impacts Identified.
 Socioeconomic Issues 21

5 SOCIOECONOMIC ISSUES
The panel's terms of reference include a review of the impact would allow participants to move in and out of the workforce
of employment and socioeconomic opportunities afforded easily. In response to this suggestion, the proponent indicated
northern residents by the proponent and the measures neces- that the labour pool may be an effective way to utilize a flexi-
sary to implement those opportunities. ble supply of labour that would be nearby and available on
short notice.
In conducting its review, the panel considered the impacts of
the proposal on individuals, their families and communities, The panel supports the proponent's pursuit of the
traditional Dene values and lifestyles, and the Athabasca re- 50%-northerner goal and urges Cameco to make every
gion generally. Specific issues addressed below are whether reasonable effort to realize it. The panel believes that
area residents obtain their share of the jobs and other benefits Athabasca Basin aboriginal people are entitled to a
that the new mining operation would generate; whether fair greater share of the jobs at Rabbit Lake, and it therefore
compensation is given for disruptions to trapping and other concludes that the proponent should, where possible, of-
traditional lifestyles; the quality of working life; and whether fer new and vacant positions to these northerners. In
area residents are adequately informed about the Rabbit Lake addition, Cameco is encouraged to double the number of
operation. full-time workers from Wollaston Lake as one way to re-
dress the imbalance in benefits received by this commu-
nity. The panel also proposes that the proponent consult
5.1 Employment with Wollaston Lake representatives to establish a labour
pool from that community.
Cameco has indicated that the proposal is likely to increase
full-time employment at the Rabbit Lake site during the
11-year life of the project by about 5% over the current level of 5.2 Other Economic Benefits to Athabasca
320 workers.
Basin Communities
In numerical terms, this modest impact would appear to offer
few opportunities for residents of the Athabasca region. The The proponent spends about $100 million a year on goods
proponent remains committed to increasing the percentage of and services in support of its overall northern mining opera-
northerners in its workforce to 50% by 1995 (a northerner is tions, and it estimates that the proposed Rabbit Lake opera-
defined by Saskatchewan as someone who has lived in north- tion would generate about $40 million worth of business
ern Saskatchewan for 10 years or one half of his or her life). annually. Twenty percent of Cameco's purchases are from
Cameco's efforts to date - raising the northern workforce par- enterprises in northern Saskatchewan, primarily in the La
ticipation from 25% in 1988 to 43% at present - suggest that Ronge area.
the corporation is determined to reach this goal.
Residents of the Athabasca Basin believe that they do not
The limited number of jobs that would be created suggests receive a fair portion of this business, and the proponent
that this goal can only be realized through a sustained effort conceded that the Wollaston Lake community has benefited
by the proponent. For example, even if northerners obtained even less than other Athabasca Basin communities. This situ-
all the new positions, participation would not reach 50%. This ation can be explained, in part, by three features of the basin:
target may be more achievable if the proponent places its weak transportation infrastructure; its underdeveloped min-
northerners in vacant positions created by turnover, even ing-support sector; and its scarcity of venture enterprises.
though the levels of turnover have been low in recent years.
Presenters suggested a number of ways to encourage the
A number of presenters stated that Cameco should ensure proponent to direct more business to communities in the
that Athabasca Basin aboriginal people are given the first Athabasca Basin. For example, the Hatchet Lake Band stated
chance to fill new and vacant positions. The logic supporting that the proponent should be required to identify one service-
this position is that, since these people are the most directly type function which could be delivered by a contractor from
affected by the mining operation, they should be entitled to Wollaston Lake. A particularly promising proposal features
most of the jobs that become available. In response, Cameco joint ventures. Joint ventures between Athabasca Basin enter-
stated that residents of the Athabasca Basin receive first prior- prises and other Saskatchewan firms to supply goods and
ity in hiring for any position at Rabbit Lake. services to the Rabbit Lake operation would increase the level
of benefits in the area and support the development of local
The proponent acknowledged that the Wollaston Lake com- entrepreneurs. Such ventures could strengthen the local
munity has not received its share of the jobs at Rabbit Lake. economies if they focused on activities compatible with tradi-
Cameco indicated that it may be possible to rectify this by tional lifestyles.
increasing the number of full-time positions occupied by work-
ers from Wollaston Lake from nine to 16 or 17. The interest in joint ventures expressed by Basin communities
and Cameco's willingness to consider practical contract pro-
Wollaston Lake representatives proposed that Cameco offset , posals indicate that such partnerships should be cultivated.
some of the traditional lifestyle opportunities displaced by the Leadership by Cameco and advice from groups that have
Rabbit Lake mine by creating a labour pool of workers from already established joint ventures, such as the Prince Albert
the community. These presenters noted that such a pool Tribal Council, would enhance the viability of these ventures.
22 Socioeconomic Issues

The panel concludes that either joint ventures or direct 5.4.1 Training
contracts with Athabasca Basin communities offer viable
means to augment the economic benefits to these com- Den§ in the Athabasca Basin expressed considerable con-
munities. Clear leadership by Cameco in this area is de- cern that their access to certain jobs at Rabbit Lake was
sirable, and the panel suggests that the proponent limited because they lacked the formal education to qualify for
consider establishing specific corporate goals to in- them. This is a serious issue, since Saskatchewan Education
crease the flow of benefits to these communities, espe- estimates that the majority of residents of working age in the
cially Wollaston Lake. The panel believes that groups Athabasca Basin have less than grade 9 education.
such as the Prince Albert Tribal Council could support
the creation of joint ventures by providing advice to the A number of aboriginal presenters questioned whether low
communities involved and by working with Cameco and levels of schooling should preclude them from technical posi-
specific entrepreneurs to implement agreements. tions with Cameco. They pointed out that in the past they had
worked in uranium mining even though they did not have the
academic credentials. The proponent indicated that it hires
5.3 Trapper Compensation many people with less than grade 10 education. Cameco
does not require a specific minimum level of education to work
The First Nation communities from the Athabasca Basin have at the Rabbit Lake operation, but rather establishes the level
a unique relationship to the land and water in the area and to meet the requirements of a specific job. Approximately 50%
have traditionally derived their livelihood from them. It is im- of the positions at Rabbit Lake now require some sort of post-
portant to note that the Den6 in the area tend to value trapping secondary education or training. These positions are primarily
more for the lifestyle it supports than the cash it generates. in the trades and in the technical and scientific areas.

The proponent admits that the Rabbit Lake operation has The panel encourages the proponent to review its educa-
affected the people's ability to use the land adjacent to the tional standards for technical positions to determine if
mine site, particularly in Block N26. In fact, Cameco recently on-the-job training is a viable alternative to these stan-
renegotiated an agreement with a local trapper to compensate dards. Cameco may find it advisable to consult with the
him for the adverse effects on his way of life caused by the appropriate government agencies where these standards
activities at Eagle Point. The company is also considering the are based on provincial norms.
claim of another trapper. The Hatchet Lake Band expressed
concern about the level of compensation provided to trappers Cameco has demonstrated a commitment to provide on-the-
and proposed that minimum guidelines be established. job apprenticeship training at Rabbit Lake for aboriginal peo-
Cameco stated that it would rather deal with trappers' com- ple from the Athabasca Basin as well as for other northerners.
pensation on a more comprehensive basis than address indi- This training gives aboriginal people access to more responsi-
vidual claims as they arise. ble technical positions at the mine and provides them with
transferable skills.
This issue raises questions about what is reasonable com-
pensation for the resulting damages. Such claims could be Several aboriginal northerners working in uranium mining ex-
dealt with on a case-by-case basis or within the context of a pressed the desire to become supervisors or managers with
more comprehensive framework that enunciates the basic Cameco. The proponent has displayed sensitivity to these
principles involved, including the method of resolving dis- aspirations. The informative presentation by the aboriginal
agreements. The panel believes that the latter approach northerner employed by the company as a personnel assis-
would help the parties better understand what to expect and tant illustrated that Cameco is making progress in this area.
would ensure that individual claims are addressed consist-
ently and equitably. The panel commends the proponent for its on-the-job
apprenticeship training program and encourages
The panel concludes that the proponent should consult Cameco to maintain and, if possible, intensify its activi-
with representatives of Wollaston Lake and the Prince ties to prepare aboriginal northerners for managerial
Albert Tribal Council to develop a framework for trapper positions.
compensation. It is desirable that Dene people, especially
elders, participate directly in creating this framework. Cross-cultural training is an effective way to facilitate partici-
pation by aboriginal northern workers in the Rabbit Lake oper-
ation. Cameco has indicated that there was mandatory cross-
5.4 Quality of Working Life cultural training at Key Lake during its initial stages. The pro-
ponent stated that the need for such training diminished as
The quality of working life includes a safe and healthy work- the number of aboriginal workers from northern Saskatche-
place, adequate training for individuals to enable them to gain wan increased and they became integrated into the mining
employment and to progress into technical and managerial environment.
positions, and work schedules that allow employees to recon-
cile their paid employment with their family and community The panel suggests that Cameco assess Its current and
activities. This broader concept of work is consistent with the ongoing need for cross-cultural training for aboriginal
Den§ tendency to perceive events in holistic terms. Worker and non-aboriginal employees at the Rabbit Lake site.
health and safety is addressed in Section 6.2; the other issues The proponent is encouraged to involve workers and
are considered below. their community representatives in this assessment.
 Socioeconomic Issues 23

5.4.2 Work Schedules communities. Indeed, a number of conclusions and recom-

mendations in this report are at least partly intended to in-
The proponent has indicated that the seven-day in/seven-day crease dialogue and cooperation between the proponent and
out work schedule contributes to efficient mining operations the communities.
and allows aboriginal workers to maintain their traditional life-
styles in northern communities. Cameco reported that it rec- Aboriginal northerners participating in the public hearings
ognizes the special needs of these workers and attempts to identified a need for better communications between Cameco
accommodate them in scheduling vacation leave. The propo- and these communities about employment and business op-
nent acknowledges that the frequent partings and reunions portunities and about mining operations. The panel recog-
caused by this work schedule can be stressful on family mem- nizes that the proponent has a northern office in La Ronge to
bers. Cameco also stated that it is considering supporting an serve this, function; however, its geographic remoteness from
independent research project on the work schedule with a the communities probably erodes its effectiveness. One way
graduate student at the University of Saskatchewan. to enhance communication may be for Cameco to appoint a
resident from the Athabasca Basin to its Board of Directors.
Several presenters expressed support for the work schedule, The panel notes that Cameco has undertaken other initiatives,
and no significant concerns were voiced about it during the such as the recently formed committee of Cameco officials
public hearings. and Athabasca Basin community representatives, to improve
communications with local residents. Despite these steps for-
In the absence of clear evidence to the contrary, the panel ward, there are still clear signs of continued misunderstand-
believes that the work schedule Is functioning relatively ings between the proponent and Wollaston Lake residents in
well. The proponent is encouraged to support the re- particular. Left to fester, these communications breakdowns
search project designed to provide more systematic In- could fuel greater mistrust and tension between the parties.
formation about the schedule. Given the interest and
insights that workers, their families, and Athabasca Basin The panel supports Cameco's recent efforts to communi-
communities have on this subject, it is suggested that cate more effectively with Athabasca Basin communities.
these groups participate in the study. The panel suggests that the proponent consider addi-
tional means to communicate with these communities,
such as arranging for the Prince Albert Tribal Council to
5.5 Proponent-Community Relations disseminate information on the Rabbit Lake operation, in
light of the unique relationship between Cameco and the
Presentations to the panel by members of Athabasca Basin Wollaston Lake community, the panel believes that these
communities, particularly Wollaston Lake, revealed that there parties should engage in direct dialogue on issues of
is room to enhance relations between Cameco and these specific concern to them.

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 Health and Safety Issues 25

6 HEALTH AND SAFETY ISSUES

The panel's consideration of health and safety issues included We are also disappointed that the proponent has
both community health and worker health and safety. Com- made very little effort to understand and appreci-
munity health addresses the definition of health, northern ate the concern of this community, and to ac-
community concerns and radiation risks to those communi- commodate those concerns. We must remind
ties. The main issues pertaining to worker health and safety Cameco that our concerns are unique.... It may
were the proponent's programs in this area, radiation risks be necessary to require that Cameco deal di-
and effects of radiation exposure. rectly with Wollaston as a condition of its operat-
ing agreement.
(Jack Bell, Wollaston Lake, July 5, 1993)
6.1 Community Health
The panel concludes that these views reflect a profound
6.1.1 Definition of Health concern that many northern residents share with regards
to this development.
The panel's technical specialists on social health issues,
Moore Chamberlin and Associates, provided many useful in- 6.1.2 Northern Community Concerns
sights, which are included throughout this section. In their
1992 report to the panel, at pages 58 and 59, Moore
Chamberlin proposed that the following common values or The perception of risk can have a negative impact on the
assumptions be used when evaluating the EIS. health of communities. Northern community concerns include
damage to the land, contamination of the aquatic environ-
ment, and changes in the distribution and abundance of fish
• Health is defined holistically as involving the mental,
and wildlife. These issues have been addressed to a large
physical, emotional and spiritual aspects of the individ-
extent in the EIS and supporting documents; however, these
ual and community. As defined by the World Health
reports have done little to reassure communities that feel they
Organization, 'health is a state of complete physical,
have been misled and betrayed by governments, outsiders
mental and social well-being and not merely the ab-
and private companies in the past. The panel has recom-
sence of disease or infirmity'.
mended the establishment of an Environmental Management
Committee to provide a mechanism for community involve-
• Equal weight must be given to the impacts of uranium ment. The panel believes that direct involvement of northern
mining on the people who are permanent northern re- communities in monitoring and their input into decisions re-
sidents as to all other beneficiaries. They must be seen garding the development of the Rabbit Lake operation would
as rightful and equal partners with any outside institu- do much to alleviate their concerns about damage to the
tions who wish to use the region for their own pur- environment.
poses. Northern residents must receive direct benefit
from industry operating in their region.
In summary, the people of the North do not feel that the
• As rightful equal partners, the values and culture of the proponent has an appreciation for the value of their land.
partners must be respected. Inherent contradictions ex- The panel concludes that the Environmental Management
ist between native cultural values and industrial values. Committee should work with Cameco to investigate ways
Considerable anxiety is associated with the change in which this perception might be mitigated, including
from a traditional land base to industrialization. This community input to monitoring of the operation and the
has resulted in anxiety and fear due to an increased use of traditional ecological knowledge in monitoring
perception of risk. This increases the negative impacts programs.
attributed to development. Activities and industry com-
ing into the North need to make efforts to improve The people of the North need to know they are not going to
knowledge, build self-reliance, reduce dependency and become ill from eating fish. The communities sought guaran-
thereby contribute positively to the health and well-be- tees that the proposed mining would not adversely effect the
ing of permanent residents of the region. health of the fish population, the health of humans who eat the
fish, or the marketability of fish.
• A community development approach is currently being
utilized for health planning and development in various The Department of Fisheries and Oceans, in reviewing the
northern locations. This approach views participation, documentation provided to the panel, presented the following
involvement and empowerment of community members information: any activity that results in members of the public
in addressing issues that affect their community as be- receiving a radiation dose of more than 1 millisievert/year
ing critical to optimizing the full individual, social and (mSv/year) should be avoided or altered. The panel was told
economic health of the community. that one person would have to consume at least 300 kg of fish
from Beaverlodge Lake to receive a dose of 1 mSv. Since
A number of these views were echoed by the community of radiation levels in Wollaston Lake are lower than in
Wollaston Lake (Hatchet Lake Band). In a presentation to the Beaverlodge Lake, even more fish would have to be con-
panel, a spokesperson for the community said: sumed to reach the same dose. Thus, it is unlikely that eating
26 Health and Safety Issues

fish from Wollaston Lake would lead to doses of 1 mSv/year 6.2 Worker Health and Safety
among members of the public.

6.2.1 Health and Safety Programs

6.1.3 Radiation Risks
Cameco stated that the mine-water spill at Rabbit Lake in
1989 caused it to reconsider its approach to environmental
The effect of radiation on people away from the mine site was and safety issues. Since the spill, Cameco has implemented a
raised. In particular, concern was expressed that radon gas number of measures to promote the health and safety of
would be carried by wind from the mine site, affecting adjacent employees at the Rabbit Lake operation.
communities.
• Cameco's Board of Directors appointed an environmental
The Radiation and Environmental Protection Division of the and workers' safety committee, which reviewed company
AECB provided the panel with information on the magnitude policy and ultimately endorsed a new environmental and
of radiological impact should the proposed development pro- workers' safety policy. The policy states that the health and
ceed. It was also pointed out that the permissible levels of safety of employees, the health and safety of the public, and
radiation for the public are generally 5% to 10% of the permis- the protection of the environment are primary concerns and
sible levels for workers at the mine site. Doses to individuals responsibilities. It goes further and demands compliance
at Hidden Bay Lodge or in the community of Wollaston Lake with both the letter and spirit of the policy, as well as with all
were estimated to be well below the regulatory dose limit for related laws, regulations and licence conditions.
the public, both with and without expansion of the mining
operation. In the post-decommissioning phase, estimated • The Rabbit Lake safety department conducts training, per-
doses to these reference groups would not significantly differ forms regular inspections, operates a radiation protection
between the expansion and no-expansion scenarios. Based program, monitors industrial hygiene and maintains trained
on these findings, the AECB considers that the potential radio- emergency teams to deal with mine accidents, fires, spills
logical impact of the Rabbit Lake development would be and transportation mishaps. There is an occupational health
acceptable. nurse on the site, and most employees have some level of
first aid qualification. Medical surveillance starts with a pre-
employment medical and continues with annual medical ex-
Environment Canada also verified that the calculated radiation aminations conducted at the site. During the hearings, there
doses to the communities far-removed from the mines, which was considerable discussion about these issues, and em-
would include the Hamlet of Wollaston Lake, would be very ployees and medical personnel verified that these proce-
low. However, Environment Canada recommended that the dures are in place.
proponent conduct radionuclide pathway analyses for local
aquatic and terrestrial food chains, not just regional food • New employees at Rabbit Lake receive basic radiation pro-
chains. Further, Environment Canada recommended radia- tection and safety training on arrival at the site. They are
tion-dose modelling for humans living year-round on or imme- subsequently enrolled in a more detailed radiation safety
diately adjacent to the site. course and receive more specific safety training on the job.

On the basis of information provided by the proponent, • There are two occupational health and safety committees,
the AECB and Environment Canada, the panel is satisfied one for each shift. These committees consist of an em-
that the radiological impact of the proposed Rabbit Lake ployee and supervisor from each department. The commit-
development on humans will be acceptable. The panel tees meet regularly, conduct safety inspections, participate
suggests that, when developing the monitoring program, in accident investigations and accompany regulatory
the Environmental Management Committee consider the inspections.
need for site-specific pathway analyses based on field
data. • For radiation protection, Cameco must have a Code of
Practice approved by the AECB. The Code of Practice de-
fines a series of action levels and specifies measures to be
Health issues pertaining to the family were not addressed taken once certain exposure levels are reached: the greater
during the hearing. For example, there is no reference to any the exposure rate, the more demanding the action required.
kind of health program planning that would address the emo- By following the Code of Practice, actions are taken before
tional needs of workers and their families and there is no individual exposures could accumulate to the point where
reference to any personal or group counselling service availa- an exposure limit might be exceeded.
ble at the workplace or away from the mine site.
The panel concludes that Cameco has demonstrated a
commitment to worker health and safety.
The panel encourages Cameco to consider the health is-
sues of workers' families. Since the panel does not think
this topic is the sole responsibility of the proponent, it is 6.2.2 Radiation Risks
proposed that Cameco consult with others involved with
health planning for the northern communities in consid- According to Cameco, radiation exposures associated with
ering family health issues. open-pit mining of the A-zone and D-zone should parallel
 Health and Safety Issues 27

those of the B-zone operation, which were well below regula- dose, measured in millisieverts, is the sum of the equivalent
tory limits. At Eagle Point, the narrow confines of the under- doses in each tissue, weighted for the risk associated with
ground operation bring the miners into closer contact with the that tissue. Thus, this unit broadly indicates the risk to health
ore and require greater ventilation. The AECB noted that from any radiation exposure regardless of type and energy of
Cameco will be required to submit updated ventilation plans the radiation.
prior to a licensing decision.
Another unit, working level (WL),' is used to quantify the
The mining methods being tested at Eagle Point, such as non- concentration of radon and its decay products in air. In mining
entry mining techniques and the use of remote-controlled environments, exposure to radon progeny is measured by
loading equipment, are designed to keep the miners away working level month (WLM), that is, the exposure resulting
from radiation sources. In general, work is organized to mini- from the inhalation of air containing 1 working level of radon
mize the time that miners spend close to the face being ac- progeny for 1 working month.
tively mined. Some exposure is inevitable during placement of
the blasting agent, but this can be minimized by good plan-
ning and efficient operation. Current AECB regulations set the dose limit at 50 mSv/year
and set the annual limit for exposure to radon progeny at 4
WLM. These regulations are based, to a large extent, on
A potentially significant source of exposure is ore collected at recommendations of the International Commission on Radio-
the draw points. Mucking of broken rock is done with scoop logical Protection (ICRP). In 1991, the ICRP published new
trams that can be controlled by an operator away from the recommendations on radiation protection. Based on ICRP
face, in low radiation fields. The principal reason for approach- recommendations, the AECB proposed a reduction in dose
ing the active face would be to repair equipment that had limit from 50 mSv/year to 20 mSv/year. These proposed
broken down. In this circumstance, another piece of mobile changes to the Atomic Energy Control Regulations are out-
equipment would be used to haul the broken equipment away lined in Consultative Document C-122 issued in July 1991 for
from the face for repair in a lower radiation field. comment by licensees and the public.

When miners have to enter higher radiation areas, they are The proponent provided data that demonstrated that the dose
issued with direct-reading dosimeters, which can be read on levels in Eagle Point were low. In the 12 months ending March
the spot. Thus radiation doses can be checked frequently 31, 1993, the average gamma radiation dose at Eagle Point
during repair or retrieval work. Should the rate of dose ac- was 1.28 mSv and the maximum was 10.2 mSv, 3% and 20%,
cumulation be excessive, the work could be terminated before respectively, of the annual limit of 50 mSv. The average radon
the accumulated dose became unacceptable. The dosimeter progeny exposure was 0.47 WLM and the maximum was 1.48
readings are monitored not only by the employee, but also by WLM, 12% and 37%, respectively, of the annual limit of 4
the supervisors, superintendents and by head office staff in WLM. During production mining, the average effective dose
Saskatoon. for Eagle Point miners is predicted to be 3.6 mSv, 18% of the
proposed new limit of 20 mSv/year averaged over a 5-year
Radon in water - a potential source of radioactivity in the period. The most exposed worker would receive 15.8 mSv,
Eagle Point mine air - was of concern to a number of 79% of the proposed limit.
presenters. The proponent responded by describing its radon-
monitoring practice. When large water flows are encountered,
the water is sampled and analyzed for radon; where neces- The effect on workers involved in milling higher grade ore from
sary, the water is handled so as to prevent the release of A-zone, D-zone and Eagle Point mine was another issue
radon into the mine air. Both continuous monitors and grab raised during the review. Cameco predicted future exposures
sampling are used to measure radon progeny in the mine air, to mill workers by extrapolating from current exposure levels.
yielding the information necessary for proper control of the These projections suggest that radiation exposures in the mill
ventilation system. would be below the proposed AECB dose limits.

The panel is satisfied that radiation protection is of uppermost

6.2.3 Effects of Radiation Exposure importance to Cameco and that it intends to keep the expo-
sure as low as reasonably achievable. As noted above, the
The AECB, in a presentation to the panel, explained that AECB has proposed amendments to the Atomic Energy Con-
several measures and units are used to quantify radiation trol Regulations that would reduce the dose limit to 20
exposure. An absorbed dose, measured in grays (Gy), is the mSv/year. Information presented by Cameco indicated that it
amount of energy imparted by radiation to a unit mass of would be able to meet the new standard proposed by the
matter such as tissue. Equal absorbed doses do not necessa- AECB with no major changes to operating plans.
rily have equal biological effects: 1 Gy imparted to tissue from
subatomic particles (such as alpha particles) is more harmful The panel therefore concludes that application of the new
than I Gy from X-rays or gamma rays. To put all types of standard to the proposed development at Rabbit Lake
radiation on an equal basis with regard to their potential for would be achievable and could result in a greater level of
causing harm, the equivalent dose is used. An equivalent worker protection. It should be noted, however, that ex-
dose, measured in millisieverts (mSv), is the absorbed dose posure levels for some workers would be close to the
multiplied by a factor that takes into account the effectiveness new limit. Greater vigilance might be necessary to ensure
of a particular radiation type in causing harm. An effective that these workers do not exceed the new standard.
28 Health and Safety Issues

The panel notes that the AECB has called for input from the
industry and public on the proposed revisions to the Atomic
Energy Control Regulations. Comments received will be used
to develop the legal wording of the proposed regulations,
which will then be published in the Canada Gazette. Before
the regulations become law, the industry and public will have
an opportunity to comment. Although the panel supports the
proposed reduction in dose limits, it would appear premature
to recommend application of this standard to the Rabbit Lake
operation until the regulatory review process is completed.
Application of a more restrictive standard to one operation
could place it at a competitive disadvantage and may also
circumvent the regulatory review process.
18. The panel recommends that the AECB complete the
consultation process on the regulatory changes
proposed in C-122 in a timely manner and make
every effort to have the revised regulations in place
before full-production mining begins at Eagle Point.
 Monitoring, Enforcement and Compliance Issues 29

7 MONITORING, ENFORCEMENT AND

COMPLIANCE ISSUES
The terms of reference for this review specifically direct the current technology and the biological effects of ef-
panel to consider the adequacy of monitoring, enforcement fluent releases. The panel urges Environment Ca-
and compliance systems to ensure that the measures neces- nada to complete this review and amend the
sary for mitigating adverse impacts can be implemented. regulations in a timely manner.
Monitoring is addressed in detail in "Environmental Issues"
(Section 4). Other issues related to this aspect of the mandate It should be noted that, although the panel is recommending
are the adequacy of regulations and guidelines; reporting of revision of the MMLER, it considers that these regulations
spills; fish habitat compensation; and financial security for establish only the minimal conditions for environmental pro-
funding decommissioning and remediation of unforeseen en- tection. The panel has recommended application of the
vironmental impacts. ALARA principle, examination of total loading to the environ-
ment and possible use of water quality guidelines as means to
further reduce impacts.
7.1 Regulations and Guidelines
Several presenters suggested that Cameco should meet the
Canadian Water Quality Guidelines (CWQG) and the Sas-
The federal Metal Mining Liquid Effluent Regulations katchewan Surface Water Quality Objectives (SSWQO) in ad-
(MMLER) authorize the discharge of effluents from mining dition to the MMLER. For example, the Department of
operations into waters frequented by fish. These regulations, Fisheries and Oceans recommended that all effluent dis-
promulgated in 1977 under the federal Fisheries Act, are ad- charges entering receiving waters should meet the criteria of
ministered by Environment Canada. The regulations apply to the CWQG, which, it contends, provide greater protection to
base metal, uranium and iron ore mines, and compliance is aquatic biota than the SSWQO. Environment Canada pro-
mandatory. For uranium mines, the MMLER effluent concen- posed that site-specific water quality objectives be developed
trations are specified in licences issued by the AECB. for Effluent Creek and Hidden Bay based on a combination of
the SSWQO, CWQG, baseline water quality conditions and
scientific requirements for protecting aquatic ecosystems. The
The MMLER set national limits for arsenic, copper, lead,
Saskatchewan Environmental Society recommended that
nickel, zinc, radium 226, total suspended matter and pH. The
Cameco be required to meet the CWQG in its Rabbit Lake
limits are based on concentrations that could be achieved with
operations.
the best practicable technology (BPT) existing when the regu-
lations were developed. In 1984, the regulations were re-
viewed and the public consulted; however, no changes were The CWQG, prepared jointly by the federal and provincial
made. The panel understands that Environment Canada is governments, set national objectives for Canadian surface
again reviewing the regulations with a view to amending them. waters but have no regulatory status. The CWQG were used
That review is considering input from a number of stakehold- to develop the SSWQO, which more specifically reflect condi-
ers, including the mining industry and environmental non-gov- tions in Saskatchewan. Like the Canadian Guidelines, the
ernmental organizations. Saskatchewan Objectives also have no legal status.

Effluent discharge from uranium mines is regulated federally

Data presented by the proponent and the regulatory agencies under the MMLER and in Saskatchewan by the Mineral Indus-
indicate that effluent discharges from the Rabbit Lake opera- try Environmental Protection Regulations. The panel notes
tion meet the MMLER. Mean annual concentrations of regu- that information provided by Cameco during the hearings indi-
lated parameters were all less than 10% of the limits in 1992. cates that the mean concentrations of metals and ra-
Similar levels of performance have been predicted for the dionuclides measured in 1992 at the mouth of Effluent Creek
mining and milling of A-zone, D-zone and Eagle Point ore. met both the CWQG for freshwater aquatic life and the
Notwithstanding, concern was expressed at the hearings that SSWQO for protection of aquatic life and wildlife. The panel
the MMLER do not cover a number of elements in the Rabbit suggests that the Environmental Management Committee
Lake effluent. For example, uranium, mercury and molybde- consider the need to apply the CWQG and the SSWQO to the
num are not regulated. Further, the MMLER consider only Rabbit Lake operation. Results of monitoring in Hidden Bay
dissolved radium whereas Saskatchewan regulates total ra- should indicate whether the application of these guidelines is
dium; this may provide a better measure of loading to the necessary.
environment. Moreover, these regulations have not been up-
dated since 1977 and do not reflect either current technology
or information on the biological effects of these releases. 7.2 Spills
19. The panel recommends that Environment Canada's A number of presenters cited the spill of mine water at the
current review of the MMLER include an examina- Rabbit Lake Operation in 1989 as the reason that the pro-
tion of the feasibility of regulating all toxic sub- posed project was referred to a panel review. Cameco ac-
stances in the Rabbit Lake effluent. Further, any knowledged that the spill did have a "profound impact" on its
revision of the regulations should take into account relationship with people in the North. In written and oral
30 Monitoring, Enforcement and Compliance Issues

presentations, the proponent described the improvements to established to guarantee that any environmental damage be
contingency plans and procedures it has implemented since adequately cleaned up. The band proposed that this fund be
the spill to prevent further occurrences. The panel is of the administered by a board that includes representation from the
opinion that the measures in place to prevent a similar spill community. In response, Cameco indicated that both the Sas-
are adequate and did not receive any information to the katchewan and Canadian mining associations are working
contrary. towards development of some form of an insurance or indem-
nification system. Further, Cameco indicated that it had initi-
Nevertheless, the panel was advised that a number of "minor" ated discussions with northern communities, including
spills had occurred at the operation since 1989. One spill Wollaston Lake, about the establishment of a warranty against
involved a truck driver who washed his truck with contami- environmental damage. The panel encourages these efforts
nated water from the mill. The issue is not so much the fact by Cameco.
that spills have occurred but rather how they were reported.
The panel was advised that certain spills were deemed to be Approval of a mining project is based on the understanding
"unreportable" if the spilled material did not enter the natural that the site can be decommissioned acceptably. After
environment. In commenting on this issue, the AECB indi- decommissioning and following a period of post-decommis-
cated that it is the practice for all spills to be reported, but it sioning monitoring, responsibility for the Rabbit Lake site will
prefers the use of the term "incident" where there is no resul- revert to Saskatchewan. The possibility that the site and asso-
tant environmental damage. ciated wastes could become a public liability, as is the case
with the Gunnar mine, is a serious public concern. The nature
The panel concludes that the current mechanism of spill of this concern is twofold. First, the proponent may not have
reporting apparently confuses the public and in some adequate resources to decommission the site, or changes in
cases leads the public to mistrust the industry and regu- company profitability or ownership may affect the availability
latory agencies. The public has the right to be informed of these funds. Second, the company may abandon the site
about spills at the Rabbit Lake operation in a timely and before the long-term effects of the wastes are known, leaving
unambiguous manner. A method of classifying and re- the government responsible for cleanup. In response to these
porting spills acceptable to the public is essential to the issues, the Saskatchewan Environmental Society proposed
maintenance of public trust. that Cameco post two bonds, one to cover the costs of
decommissioning and the second to cover long-term monitor-
20. The panel recommends that the Environmental ing and maintenance of the site following abandonment.
Management Committee review the method of clas-
sifying and reporting spills and recommend any
Cameco estimated that decommissioning and reclamation of
changes to ensure that the public is clearly in-
the Rabbit Lake operation would cost $17.5 million. Further,
formed of the nature and effects of all spills at the
Cameco stated that its policy on financial commitment for
Rabbit Lake operation.
decommissioning and reclamation costs would be to accrue
provisions for these costs and to have cash flows and finan-
7.3 Fish Habitat Compensation cial liquidity to fund this work as required. Cameco indicated
that at the end of 1992, it had a total accounting provision of
Mining of the A-zone and D-zone orebodies would result in $45.8 million for decommissioning and reclamation of all of its
the loss of an estimated 14.2 hectares (ha) of fish habitat in operations.
Collins Bay. Detailed information on fish use of this habitat
was not presented by the proponent. The Department of Fish- The panel concludes that the proponent's accounting ap-
eries and Oceans advised the panel that under its Policy for proach does not provide sufficient certainty that ade-
the Management of Fish Habitat, the proponent would be quate funds would be available at the time of
expected to enter into a Fish Habitat Compensation Agree- decommissioning.
ment with the department to ensure that there is "no net loss"
of the productive capacity of fish habitat. Further, Cameco Although final decommissioning of the site cannot occur until
would also be expected to apply for a Fish Habitat Authoriza- mining and milling of the ore are completed, certain aspects of
tion from the Minister of Fisheries and Oceans that would the operation can be decommissioned now. For example,
permit the destruction of fish habitat in Collins Bay. The panel decommissioning of the B-zone pit and the original Rabbit
notes that, should mining of the A-zone and D-zone be ap- Lake tailings pile has already been initiated. Further, Cameco
proved, the proponent should allow sufficient time to conduct proposed a number of studies to identify decommissioning
the studies necessary to develop a compensation plan to the options for other aspects of the operation. The panel encour-
satisfaction of the Department of Fisheries and Oceans. ages these initiatives, since they will reduce the amount of
work, and therefore funds, required to finally decommission
the site. If the proponent can demonstrate that various as-
7.4 Financial Security pects of the operation have been successfully decommis-
sioned, then public confidence and trust in Cameco's ability
Provision of financial security to fund remediation of unfore- and commitment to decommission the site should increase.
seen damage to the environment and to ensure that the site is As previously recommended, the involvement of the Environ-
adequately decommissioned was an important issue at the mental Management Committee in developing a comprehen-
hearings. The former was specifically addressed by the sive decommissioning plan is essential to ensure that there is
Hatchet Lake Band, which requested that a trust fund be public input into this plan.
 Monitoring, Enforcement and Compliance Issues 31

The AECB is proposing to revise the Uranium and Thorium The panel concludes that the proposed amendments to
Mining Regulations under the Atomic Energy Control Act to the Uranium and Thorium Mining Regulations may not be
ensure that the costs of decommissioning of current and fu- sufficient to satisfy the concerns raised by many
ture licensed uranium mining facilities would be borne by the presenters. It is the panel's view that bonding, or other
licensee and not by the public. However, the information sup- forms of financial security that cannot be used by the
plied by the AECB states that these amendments "...will not company except for decommissioning, is required.
ensure that funds are available at the time that any
decommissioning work is required to be carried out as 21. The panel recommends that the Minister of Natural
that would require direct acquisition by the crown of a Resources consider either proposing amendments
licensee's assets. The power to acquire assets can only to the Atomic Energy Control Act or tabling other
be obtained through legislation, which the AECB will pur- legislation that will provide for bonding or an
sue as soon as possible." The AECB is currently consulting equivalent form of financial security for decommis-
with stakeholders on these proposed revisions. sioning of the Rabbit Lake operation.

NEXT PAOS(S)
left BLANK
 Other Issues 33

8 OTHER ISSUES

The issues addressed below merit comment, even though Quality of the Environmental Impact Statement
they are beyond the panel's mandate, since they raise policy
and procedural issues that deserve further consideration by A number of presenters expressed concern about the quality
those responsible for reviews in these areas. of the documents supplied by the proponent. Specific con-
cerns were that some of the information in the 1992 revised
EIS was incomplete and out-of-date. Another frequent criti-
8.1 Public Review Process cism of the EIS was that it was not reader-friendly. Indeed,
several participants in the public hearings cited these short-
comings as impediments which made it more difficult for them
Panel Mandate and Issues Concerning Nuclear to analyze and evaluate the proposal under review.
Fuel
The panel notes the concerns and understands the frustration
expressed by these presenters. The panel also found the
As the panel stated in the hearings, its terms of reference
weaknesses made the environmental assessment process
directed it to consider the environmental, health, safety, and
more demanding. In fact, in November 1992 and in May and
socioeconomic impacts of the proposed uranium mining facil-
June 1993, the panel had the proponent submit supplemental
ity at Rabbit Lake. These terms of reference explicitly pre-
information to overcome these shortcomings.
cluded the panel from examining the relative merits of
generating electricity or the policies of the governments of
Canada or Saskatchewan concerning uranium mining, ura- The panel believes that the sheer volume of documents, as
nium exports and nuclear non-proliferation. well as the difficulty of reading them as a whole, partially
explains why more than a few presenters admitted that they
had either not consulted or not understood these documents.
Most presenters therefore focused their comments on the
specific project under review. Some participants, however, felt
In general, the panel concludes that proponents would be well
compelled to express their views on a range of issues includ-
advised to devote the necessary time and effort to ensure that
ing energy options facing Canadians; the use of full-cost ac-
EISs are clear, complete and up-to-date. This extra initial
counting to gauge the efficacy of uranium mining; the nuclear
effort could well save all parties considerable work and worry
fuel cycle; disposal of high-level nuclear waste; the advisabil-
later in the assessment process.
ity of mining uranium when its price is low; and the end use of
uranium.
Two Uranium Mining Panels
The frequency with which participants voiced fundamental
concerns about the link between uranium mining and the end Even though the panel chair drew a clear distinction between
use of the product raises two key points meriting comment. this review and the federal/provincial panel examining sepa-
First, such concerns suggest the public is worried about nu- rate projects in different northern locations, the existence of
clear war and deeply sceptical about Canadian and interna- two panels concerned a number of participants. Essentially,
tional safeguards against non-proliferation of nuclear these concerns were fourfold. First, some presenters raised
weapons. Second, these concerns reveal that many partici- issues such as revenue sharing that were pertinent in the
pants believe that it is only through the environmental assess- other review but beyond this panel's scope. Second, and re-
ment of specific projects that they can participate in lated to the first, a number of presenters expressed disap-
deliberations about energy and related policy choices. pointment that provincial government representatives did not
attend the hearings to answer their questions on provincial
issues related to the Rabbit Lake proposal. Third, some
In fact, both ongoing policy discussions within Saskatchewan presenters criticized governments for creating duplication and
and Canada, and the federal policy and program environmen- thereby spending public funds poorly. Finally, the fact that the
tal review process, grant citizens the opportunity to make their two reviews were staged within a matter of months of one
views on these matters known. As such, these presentations another appeared to have drained certain participants and
seem to indicate that the other processes are not fully satisfy- thus may have diminished the quality of certain presentations
ing citizens' needs to be heard. Perhaps such needs could be to this panel.
met, in part, if greater efforts were made to inform citizens of
their right to participate in these reviews.
Time Available for Public Hearings
In sum, while the panel does not deal substantively with these
issues in this report, it does wish to indicate that these In contrast with those who viewed this review as somewhat
thoughtful and diverse viewpoints, documented in the tran- repetitive, some presenters expressed frustration with the
scripts, are a rich record of public views which those undertak- amount of time available for the public hearings since, in their
ing policy reviews in these areas would be well advised to view, not all the salient issues raised had been discussed - let
consult. alone analyzed - in sufficient detail.
34 Other Issues

The panel recognizes that some participants found the public Revenue sharing is a long-standing goal of residents of north-
hearing process restricting because it involved detailed dis- ern Saskatchewan. Several independent reviews have advo-
cussions of a wide range of major issues in a relatively short cated this. For example, both the Cluff Lake and Key Lake
period of time. Boards of Inquiry, in 1978 and 1981 respectively, recom-
mended that revenues be shared with northerners. In this
review, a number of presenters in southern Saskatchewan
8.2 Provincial Issues Raised endorsed the principle of revenue sharing for aboriginal
northerners since they viewed it is a matter of natural justice.
Revenue Sharing Furthermore, spokespersons for the uranium industry in the
province and the proponent expressed support for this goal,
Several aboriginal northerners referred to the area around the noting, however, that this issue primarily involves the provin-
proposed project as "Den6 land". They stated that they should cial government and northerners.
be compensated for the mine's intrusion, which would disrupt
their traditional lifestyles and cause environmental, social, and The panel notes these viewpoints and expresses the hope
physical harm to their peoples. In addition to direct payments that the appropriate government agencies will take action to
to trappers disturbed by the project, these presenters argued address this issue soon.
that they are entitled to other compensation from Cameco and
to a larger share of the revenue generated by mining in the
area.
 Recommendations 35

9 RECOMMENDATIONS
1. The panel recommends that full-production under- a) Assess whether the properties of the tailings are
ground mining at Eagle Point be allowed to proceed consistent with those used when the facility was
under the conditions described within the report. designed.
2. The panel recommends that mining of the A-zone and b) Calibrate and update predictive models on contam-
D-zone orebodies not proceed until information on inant transport in the receiving environment using
waste-rock management and decommissioning is ob- data from field testing of the B-zone tailings, Rabbit
tained and until Cameco has demonstrated that both Lake tailings, Rabbit Lake waste rock and B-zone
short- and long-term adverse environmental impacts waste rock.
are mitigable.
c) Determine the appropriate tailings' properties, in-
3. The panel recommends that the Joint Review Group be cluding permeability and porosity, by field testing.
restructured and expanded to create an Environmental
Management Committee for the Rabbit Lake operation. d) Determine the permeability and relevant hydraulic
The panel recommends that the AECB consult directly properties of all surrounding rock units by field
with stakeholders to establish the nature of their repre- testing.
sentation. Further, non-governmental participants
should be compensated for their time and out-of-pocket e) Define the quality of pore water in order to estimate
expenses. The panel suggests that funds collected by the quality of water that may reach the receiving
government from the industry be used to finance these environment.
expenses.
f) If the water cover option were to be selected for
4. The panel recommends that the Environmental Man- decommissioning the pit, predict the long-term
agement Committee and the proponent determine and quality of surface water and surrounding ground-
implement mechanisms for greater community involve- water using three-dimensional flow or geochemical
ment in the monitoring program. models.
5. The panel recommends that the AECB and other appro- g) Maintain a detailed inventory of the chemical and
priate agencies make their services available to the physical characteristics of tailings deposited in the
communities to assist in the development and imple- facility.
mentation of education and training programs.
9. The panel recommends that mining of A-zone and
6. The panel recommends that Cameco develop a waste-
D-zone not proceed until the proponent has demon-
rock management plan for the A-zone and D-zone
strated that the B-zone pit and waste-rock pile can be
orebodies and that mining of these orebodies not pro-
decommissioned without significant adverse environ-
ceed until the plan has been reviewed and approved.
mental impacts and that detailed plans for decommis-
The plan should include the following essential
sioning of A-zone and D-zone pits and waste rock have
elements:
been prepared and approved. The proponent should
a) a waste-rock classification scheme that can be jus- demonstrate that these plans meet the ALARA
tified on the basis of environmental protection and principle.
on meeting the ALARA principle;
10. The panel recommends that Cameco initiate the studies
b) confirmation that the proposed classification required to develop a comprehensive decommissioning
scheme will separate waste rock reliably from spe- plan. In the panel's view, some of the essential ele-
cial waste and ore; ments in this plan are the following:
c) impact predictions that fully consider the conditions a) the evaluation of existing water-quality standards to
in the natural environment that will receive the determine whether these represent adequate
waste; and targets for decommissioning or whether site-spe-
d) monitoring requirements to determine if the predic- cific standards are required;
tions are correct, to identify impacts not predicted b) the development and validation of models to evalu-
and to provide data for the development of decom- ate the environmental effects of various decommis-
missioning plans. sioning options and the development of a
7. The panel recommends that the Environmental Man- decommissioning strategy that meets established
agement Committee develop criteria to evaluate the targets;
proposed waste-rock management plan.
c) the establishment of baseline conditions and deter-
8. The panel recommends that Cameco implement a com- mination of the nature and extent of a post-decom-
prehensive monitoring and assessment program for the missioning monitoring program that will be used to
Rabbit Lake tailings pit. As part of this program, evaluate the environmental effects of decommis-
Cameco should undertake the following tasks. sioning activities; and
36 Recommendations

d) an estimate of the time frame and financial re- 15. The panel recommends that Cameco implement a de-
sources required to complete the decommissioning tailed monitoring program that meets the requirements
program. developed by the Environmental Management
Committee.
11. The panel recommends that Cameco investigate means
to reduce the amount of water that requires treatment
and the amount of freshwater used. These reductions 16. The panel recommends that the Environmental Man-
would decrease contaminant loading to Hidden Bay and agement Committee identify research needs and estab-
thus achieve the goal of the ALARA principle with re- lish communication with those (e.g., universities,
spect to potential impacts on the biophysical environ- research institutes) that have the resources and abilities
ment. Investigation of water use at the Rabbit Lake to conduct the research.
operation should include the following:
17. The panel recommends that the Environmental Man-
a) the consideration of improved milling and water- agement Committee provide input into the design of
treatment processes that would result in lower con- engineering and monitoring programs and evaluate the
taminant loadings; results of these programs to identify any cumulative
effects of additional development at Rabbit Lake and to
b) an investigation of ways to use uncontaminated
recommend ways to address any impacts identified.
mine-site runoff and mine water in the mill to re-
duce freshwater consumption;
18. The panel recommends that the AECB complete the
c) the reassessment of groundwater inflows to the consultation process on the regulatory changes pro-
Eagle Point mine and, if approved, A-zone and posed in C-122 in a timely manner and make every
D-zone mines to identify options for further reduc- effort to have the revised regulations in place before full-
ing volumes of contaminated mine waters; and production mining begins at Eagle Point.
d) the examination of alternative methods of placing
19. The panel recommends that Environment Canada's
tailings in the pit and operation of the facility to
current review of the MMLER include an examination of
reduce the amount of contaminated water pumped
the feasibility of regulating all toxic substances in the
from the facility.
Rabbit Lake effluent. Further, any revision of the regula-
12. The panel recommends that results of the crown-pillar tions should take into account current technology and
monitoring program and any significant changes in the the biological effects of effluent releases. The panel
design of the pillar be provided to the Environmental urges Environment Canada to complete this review and
Management Committee. amend the regulations in a timely manner.-
13. The panel recommends that, to rectify the inadequacies
20. The panel recommends that the Environmental Man-
in the baseline and monitoring data, the Environmental
agement Committee review the method of classifying
Management Committee undertake a complete review
and reporting spills and recommend any changes to
of the current monitoring program and recommend
ensure that the public is clearly informed of the nature
changes to meet community, scientific and regulatory
and effects of all spills at the Rabbit Lake operation.
requirements.
14. The panel recommends that Cameco undertake a com- 21. The panel recommends that the Minister of Natural Re-
prehensive baseline study that can be used to monitor sources consider either proposing amendments to the
and assess the effects of additional development at the Atomic Energy Control Act or tabling other legislation
Rabbit Lake site. The baseline study should meet the that will provide for bonding or an equivalent form of
requirements developed by the Environmental Manage- financial security for decommissioning of the Rabbit
ment Committee. Lake operation.
 RABBIT LAKE URANIUM MINE
ENVIRONMENTAL ASSESSMENT PANEL

K. Wayne Hindmarsh
(Chair)

Dennis Lehmkuhl lonald Martin

NEXT PAGE(S)
left BLANK
 39

APPENDIX A

PANEL MEMBER BIOGRAPHIES

DR. K. WAYNE HINDMARSH (Chair) DR. DENNIS LEHMKUHL

Dr. Hindmarsh is Dean of the Faculty of Pharmacy at the Dr. Lehmkuhl is Professor of Biology at the Department of
University of Manitoba. Biology, University of Saskatchewan. He received his M.Sc. in
zoology from the University of Montana and his PhD in ento-
Or. Hindmarsh received a PhD from the Faculty of Pharmacy mology from Oregon State University.
and Pharmaceutical Sciences at the University of Alberta in
1970. He was a professor in the College of Pharmacy at the Dr. Lehmkuhl has been a member of the faculty of the Depart-
University of Saskatchewan from 1979 to 1992. ment of Biology since 1969, has taught extensively in the field
of biology, and is well-respected in the field of entomology. He
Dr. Hindmarsh is a former president of the Pharmacy Examin- has numerous publications on the functioning of northern
ing Board of Canada and of the Canadian Society for Forensic aquatic ecosystems, including entomological functions, and
Science, and is a member of the Canadian Pharmaceutical has research interests in potential environmental disturbances
Association. As well, he is president and member of the Board of these ecosystems. Dr. Lehmkuhl is actively involved in a
of Directors of PRIDE (Parent Resources Institute for Drug number of professional organizations, and has served as
Education) Canada Inc. He received the Meritorious Service chairman of the Review of Environmental Impact Studies
Award of the Canadian Pharmaceutical Association in 1989, Committee with the Biological Survey of Canada. He has also
and the H. Ward Smith Award for toxicology research acted as referee for editors of a number of biological journals,
presented by the Canadian Society of Forensic Science in including the Canadian Water Resources Journal and the Ca-
1990. nadian Journal of Zoology.
Dr. Hindmarsh's research interests include drug and sub- DR. RONALD MARTIN
stance abuse, drug toxicity and poisoning.
A member of the Fond-du-Lac Band, Dr. Martin is a dentist,
MR. CHARLES W. PELLEY * currently living in Saskatoon, Saskatchewan. He is actively
engaged in establishing dental services to native communities
Mr. Pelley is an Assistant Professor in the Department of throughout Saskatchewan. Dr. Martin graduated from the Col-
Mining Engineering at Queen's University. He is presently lege of Dentistry at the University of Saskatchewan in 1990
completing his Doctorate in Mining Engineering at McGill Uni- and performed an internship providing dental services to the
versity. Mr. Pelley holds a Masters of Mining Engineering from communities of Fond-du-Lac and Black Lake, Saskatchewan.
McGill University and a Bachelor of Science in Geology from He received an Advanced B.A. in Sociology and an Advanced
Memorial University. B.Sc. in Anatomy from the College of Arts and Science of the
University of Saskatchewan. Dr. Martin has also completed a
Mr. Pelley's research interests include the development of
Native Law Program at the University of Saskatchewan.
new technology for materials handling in both open-pit and
underground mines, and in the economic assessment of mine Dr. Martin's professional interests lie in establishing dental
sequencing strategies. Mr. Pelley has extensive experience in service clinics for native communities throughout Saskatche-
the mining industry and has held a number of senior opera- wan. He recently completed a one-year term with the North-
tional positions with several Canadian mining companies. ern Outreach Program, University of Toronto, providing dental
service to the people living in the area of Moose Factory,
Ontario.

* Mr. Pelley resigned from the panel prior to the hearings phase for
medical reasons.
40

APPENDIX B

SECRETARIAT AND TECHNICAL SPECIALISTS

Panel Secretariat
John Mathers Executive Secretary
John McEwen Technical Advisor
Mike Lascelles Technical Advisor
Jackie Kelly Office Administrator
Technical Specialists

Clifton Associates Ltd.

Uranium Mining Engineering Issues

Ecologistics Limited
Cumulative Effects
Environmental-Social Advisory Services (ESAS) Inc.
Employment and Socioeconomic Issues
Moore Chamberlin and Associates
Social Health Issues
 41

APPENDIX C
TERMS OF REFERENCE FOR AN ENVIRONMENTAL ASSESSMENT
REVIEW OF THE PROPOSED DEVELOPMENT OF THE
URANIUM MINING FACILITY AT RABBIT LAKE

Mandate the policies of the governments of Canada or Saskatchewan

concerning uranium mining, uranium exports and nuclear non-
The environmental assessment panel is to undertake a review proliferation.
of the environmental, health, safety and socio-economic im-
pacts of the proposed development of the uranium mining Review Procedures
facility at Rabbit Lake in northern Saskatchewan. The panel
will include in its review: Detailed written procedures for conducting the review shall be
established by the panel and made available to the public.
— the short and long-term impacts of the proposed develop-
ment, spanning the construction phase, operating period, Technical Experts
decommissioning and post-decommissioning phases;
The panel may secure the services of independent technical
— the cumulative impacts of the existing operation and the experts to assist and advise on complex technical and/or
proposed development; socio-economic issues related to its mandate. Such experts
will also be available to respond to inquiries from review
— the impact of employment and socio-economic opportuni- participants.
ties afforded northern residents by the proponent and the
measures necessary for implementation of those Stages of the Review
opportunities; 1. Review by the panel and the public of the Environment
Impact Statement (EIS) submitted by the proponent.
— the adequacy of measures proposed by the project propo-
nent to protect environmental quality and to safeguard 2. Should the panel, after reviewing the EIS and consider-
worker health and safety, and whether the measures can ing public comments, deem the EIS deficient, it may
be expected to meet the requirements of Canadian and request additional information from the proponent.
Saskatchewan law, regulations and policies applicable to
uranium mining; 3. Once the panel is satisfied with the information pro-
vided, it will schedule and announce public hearings on
— the adequacy of monitoring, enforcement and compliance the project. The location of the hearings will be decided
systems to ensure the measures necessary for mitigating by the panel.
adverse impacts can be implemented; and
4. The panel will conduct the hearings in a non-judicial but
— the benefits afforded by the proposal. structured manner to allow for a full and fair examination
of all information received by the panel and to solicit
The panel shall consider and report on the environmental and public comment on matters relevant to its mandate.
socio-economic acceptability of the project. If the panel con-
5. When the panel is in a position, following the public
cludes that the project is acceptable, it may recommend terms
hearings, to provide a report on its findings, conclusions
and conditions under which the project could proceed. If the
and recommendations, it will submit the report to the
panel concludes that the project is unacceptable, it shall pro-
Ministers of Environment and of Energy, Mines and Re-
vide its rationale for this recommendation.
sources. All reasonable efforts should be made to have
The mandate of the panel does not include a review of the this report completed by the summer of 1992.
relative merits of the various means of generating electricity or
42

APPENDIX D

BIBLIOGRAPHY OF REVIEW DOCUMENTS

Environment Impact Statement, Collins Bay A-zone, Collins Bay A-zone, D-zone and Eagle Point Development,
D-zone and Eagle Point Development, Revised 1992. Pre- June 8 - July 5, 1993.
pared by Environment and Safety Department, Cameco
Corporation. Written Submissions received during the Public Hearings
on the Collins Bay A-zone, D-zone and Eagle Point Devel-
Addendum, Environment Impact Statement, Collins Bay opments (see Appendix F).
A-zone, D-zone and Eagle Point Development. Prepared
by Environment and Safety Department, Cameco Corpo- Assessment of Social' Health Issues addressed in the
ration, March, 1993. Rabbit Lake Uranium Mine Environmental Impact State-
ment. Prepared for the Rabbit Lake Environmental Impact
Response to Panel Questions and Concerns on the Ad- Assessment Review Panel by Moore Chamberlin and As-
dendum. Prepared by Environment and Safety Depart- sociates, Saskatoon, Saskatchewan, 1992.
ment, Cameco Corporation, May, 1993.
Final Report, Cluff Lake Board of Inquiry, E.D. Bayda,
Compilation of Submissions on Environmental Impact Chairman, 1978.
Statement, Collins Bay A-zone, D-zone and Eagle Point
Development. Prepared by Rabbit Lake Uranium Mine En- Key Lake Board of Inquiry Report, R.W. Mitchell, Chair-
vironmental Assessment Panel, November, 1992. man, 1981.

Transcript of the Public Hearings held by the Rabbit Lake

Uranium Mine Environmental Assessment Panel on the
 43

APPENDIX E

SCHEDULE OF PUBLIC HEARINGS - 1993

June 8 Black Lake June 14-16 Saskatoon

June 9 Fond-du-Lac June 17-18 Regina
June 10 La Ronge June 28-30 Saskatoon
June 11 Prince Albert July 5 Wollaston Lake

APPENDIX F

SUBMISSIONS TO THE PANEL

Eli Adam Greg Chatterson

Anderson/Fast Marketing Solutions (Doug Fast)* Citizens Concerned About Free Trade (David Orchard)*
Association of Consulting Engineers of Saskatchewan (E.J. Clifton Associates Ltd. (Wayne Clifton)*
Hinz)* Fred Clipsham*
Association of Professional Engineers of Saskatchewan (Reg Ann Coxworth*
Briggs)* CUSO (Don Kossick)*
Athabasca Airways (Tim Glass)* Dene Airways (Dave Webester)
Atomic Energy Control Board (Larry Chamney, George Jack, Able Denechezhe
Rick McCabe, Mary Measures, Kevin Scissons, Tom Discovery Travel (Bob Nicholson)*
Viglasky)* Robert Doucette*
BB Health Physics Services (Dennis Brown)* Economic Development Authority of Saskatoon (Jim Yuel)*
Linda Batty Energy Mines and Resources Canada (Richard Williams)*
Bearing and Transmission Ltd. (Paul Zehr)* Environment Canada (Dennis Lawson)
Ed Benoanie* Environmental Monitors of the Athabasca Region (Dennis
Gordon Blaylock; Martin Marietta, Oakridge Laboratory* Robillard)*
Edwin Bonnaleye Kim Epp*
Ann Boulton Fisheries and Oceans Canada (Bruce Fallis)*
Carla Braidek* Beryl Forgay*
Brankohle Transport (Donna Goertzen)* Maria Fortugno*
Douglas Bruno Stefania Fortugno*
Chris Buhler* Joe Froese
Cameco Corporation (Bill Allan, Garry Anderson, Stan Frost, Louise Gagne*
Gerald Grandey, Wayne Iron, Jamie Mclntyre, Walter David Geary*
Smith, Bob Wyka)* Isabelle George*
Canadian Coalition for Nuclear Responsibility (Gordon Gibson Holdings Ltd. (Curtis Gibson)*
Edwards)* Hatchet Lake Indian Band (Jean-Marie Tsannie, Jack Bell)*
Canadian Nuclear Association (Ian Wilson)* Shirley Hauta*
Canadian Nuclear Society (Anis Dagher)* Ralph Helmuth*
Caribou Management Board (Ben Denechezhe)* David Hiebert*
Gordon Carle Cathy Holslander*
Srini Chary* IW Camp Site Caterers (William Smith)*
44

Industrial Mechanical Corporation (J.A. Wall)* Michael Poellet*

Inter-Church Uranium Committee (Philip Penna, Marvin Brent Pomeroy*
Resnikoff)* Porcupine Plains Opportunities Program (Carl Kwiatowski)*
Intergroup Consultants Ltd. (Cam Osier)* Prince Albert Development Corporation (Duane Hiebert)*
Inuit Tapirisat of Canada (Jamie Kneen)* Tim Quigley*
Walter Keyes* Peter Robillard
George Khachatourians* Simon Robillard
Kitsaki Development Corporation (Joe Roberts)* SENES Consultants Ltd. (Douglas Chambers)*
Heather Kleiner* SRK Consultants (Andy Robertson)*
Helen Kobelsky* Saskatchewan Environment and Resource Management (Ron
Croft Kylo Zukowsky)*
Jim Laban Saskatchewan Environmental Society (Peter Prebble)*
Terry LaBrash* Saskatchewan Government Employees Union (Fiona
Lafarge Canada Inc. (Ken Ward)* Bishop)*
Marlene LaRocque* Saskatchewan Mining Association (Garth Moore)*
LaRonge and District Chamber of Commerce (Peter Kelly)* Saskatchewan Natural History Society (Jim Elliott)
LaRonge Economic Development Committee (Ron Spooner)* Saskpower Corp., Northern Enterprise Fund (Ben Siemens)*
Town of LaRonge (Morris Gabrush)* Saskatoon Chamber of Commerce (Dwight Percy)*
Victor Lau Saskatoon Indigenous Coalition (Jackie Barclay, Dan Stifle)*
Steve Lawrence Saskwatch (Paul Hanly, Larry Morris)*
Bart MacDonald Maisie Shiell*
John MacDonald Siemens Transport Ltd. (Brian Smith)*
Niel Martin Adelle Smillie*
Madge McConnell* Miriam Smith*
Alex Mercredi Snake Lake Construction (Rene Rediron)
Louis Mercredi Carol Stang*
Napoleon Mercredi Gabriel Steene
Bill Metke J.G. Strnad*
Mid-north Mine and Safety Supply (Martin Arndt)* Stephanie Sydiaha*
Millennium III Properties Corp. (E.J. Kearley)* Synergy Today (Bill Childerhose)*
Linda Murphy Allan Taylor*
David Myers* Patricia Thomas*
Norpro Developments (Scott Christianson)* Freddie Thorassie
Jan Norris* Thyssen Mining Ltd. (Andy Fern)*
North Yanke Transfer Ltd. (Russell Marcoux)* Uranerz Exploration and Mining Ltd. (Hikmet Akin, Roland
Northern Industrial Plating (Heidi Schellenberger)* Loewer)*
Northern Resource Trucking (Roger Olysowsky)* Uranium Saskatchewan Association (Tim Meadly)*
Dan Parrott Van Waters and Rogers Ltd. (Lionel DeBray, Doug James)*
The Partnership (Jim Woytiuk)* Visions North Community Futures Committee (Angus Pratt)*
James Penna* Karen Weingeist
Marion Penna* Criss Wiercinski*
Grace Pine*

*A written submission was provided and is available for public

review.
 45

APPENDIX G

GLOSSARY

Active face The surface exposed by excavation at Filter cake The compacted solid or semi-solid
the end of a tunnel heading or at the material separated from a liquid and
end of a full-size excavation. remaining on a filter after pressure fil-
tration.
Alpha particle A positively-charged particle emitted
by a radionuclide and composed of Gamma radiation A high energy photon, especially as
two protons and two neutrons. emitted by a nucleus in a transition
between two energy levels.
Beta particle A negatively-charged particle emitted
from the nucleus of an atom, with a Geochemistry A science that deals with the chemical
mass and charge equal in magnitude composition and chemical changes in
to that of an electron. the solid matter of the earth.
Clarifier A centrifuge, settling tank or other de-
Geologic strata Beds or layers of rock.
vice for separating suspended solid
matter from a liquid. Gray One gray is the amount of energy im-
Crown pillar A undisturbed rock mass left between parted by radiation to a unit of mass of
the top of an underground excavation matter such as tissue.
and the surface.
Groundwater All water below the ground surface.
Cumulative effect The result of a series of successive
actions or impacts; in the context of Hydraulics A branch of science that deals with the
the environment, a succession of im- motion of liquids.
pacts from the same or different A science that deals with the charac-
sources that, taken together, result in Hydrogeology ter, source and mode of occurrence of
a change to an ecosystem. underground water.
Curie A unit of radioactivity defined as that
A science dealing with the properties,
quantity of any radioactive nuclide Hydrology distribution, and circulation of water on
which has 3.7 x 1010 disintegrations
the surface of the land, in the soil and
per second.
underlying rocks and in the atmos-
Cut-off grade The lowest grade of mineralized rock phere.
that is quantified as ore in a given de-
posit. Infiltration The deposition of a mineral among the
pores of a rock by the permeation of
Decline A downward slope. the percolation of water carrying it in
solution.
Decommissioning The process of removing a facility
from service. Leachate A solution or product produced by a
liquid percolating through the soil or
Dose The amount of energy imparted by
other medium.
ionizing particles to a unit of mass of
irradiated material at the point of inter- Limnology The scientific study of the physical,
est. chemical and biological conditions in
Dosimeter An instrument that measures the total fresh waters.
dose of radiation in a given period. One of a group of animals without a
Microinvertebrate
Dyke A barrier constructed to prevent the backbone; generally consisting of
passage of water. plankton, bacteria and protozoa.

Epidemiology A branch of medical science that Mucking The operation of loading broken rock
deals with the incidence, distribution by hand or machine usually in shafts
and control of disease in a population. or tunnels.
46

Nuclide A species of atom characterized by Special waste Waste requiring greater levels of treat-
the number of protons, number of ment due to the nature or concentra-
neutrons, and energy content in the tion of contaminants it contains.
nucleus, or alternatively by the atomic
number, mass number and atomic Stakeholder Government or non-government par-
mass. ties with an interest in or responsibility
for a project under review.
Overburden Material overlying a deposit of useful
geological materials or bedrock. Stave tank A tank constructed of narrow strips of
wood placed edge to edge to form the
Pore water Free water present in the soil or other sides.
materials.
Stope A step-like excavation underground
Radioactivity The property of certain unstable nu- for the removal of ore that is formed
clides to spontaneously undergo nu- as the ore is mined in successive lay-
clear transformations that result in the ers.
emission of ionizing radiations.
Tailings Residue produced during the milling of
Radionuclide A nuclide that exhibits radioactivity. ore consisting of finely ground rock
and chemical precipitates.
Radon A heavy radioactive gaseous element
formed by the disintegration of radium. Taxonomy The orderly classification of plants and
animals according to their presumed
Radon progeny The four radioactive, short-lived decay natural relationships.
products of radon: polonium-218,
lead-214, bismuth-214, and polonium- Voucher specimen A sample or specimen permanently
214. retained and accessible in the event
that reanalysis is necessary or confir-
Raise A vertical or inclined opening or pas- mation of the identification is required.
sageway connecting one mine work-
ing area with another at a higher level. Working level One working level corresponds to a
concentration of 100 picoCuries per li-
Scoop tram A vehicle used to remove broken ore tre of air.
from the bottom of the stope.
Seal water Water maintained under pressure to
provide a seal between a contaminat-
ed fluid and a bearing to prevent con-
taminants from reaching the bearing.