MINISTERIAL APPROVAL UNDER THE ENVIRONMENTAL ASSESSMENT ACT RABBIT LAKE SOLUTION PROCESSING PROJECT Cameco Corporation and AREVA Resources Canada Inc.

Size: px
Start display at page:

Download "MINISTERIAL APPROVAL UNDER THE ENVIRONMENTAL ASSESSMENT ACT RABBIT LAKE SOLUTION PROCESSING PROJECT Cameco Corporation and AREVA Resources Canada Inc."

Transcription

1 MINISTERIAL APPROVAL UNDER THE ENVIRONMENTAL ASSESSMENT ACT RABBIT LAKE SOLUTION PROCESSING PROJECT Cameco Corporation and AREVA Resources Canada Inc. REASONS FOR DECISION Introduction Section 16(1) of The Environmental Assessment Act (the Act) states that, where a proponent has received ministerial approval to proceed with a development, no proponent shall make a change in the development that does not conform to the terms or conditions contained in the ministerial approval. A change to an approved development requires a Ministerial decision under section 16(2) of the Act. In January 2005 Cameco Corporation (Cameco) and AREVA Resources Canada Inc. (AREVA) submitted a proposal to the Ministry of Environment (the Ministry) seeking approval to transport partially-processed uranium-rich solution (URS) from the JEB mill at AREVA S McClean Lake uranium mining and milling development to the Rabbit Lake mill at Cameco s Rabbit Lake uranium mining and milling development for final processing (the Rabbit Lake Project). The uranium, as URS, that would be transported to Rabbit Lake would come from the Cigar Lake uranium mine that is jointly owned by Cameco and AREVA. As previously approved under the Act, all Cigar Lake ore would be transported to the JEB mill at McClean Lake for final processing. The URS that would be transported from McClean Lake to Rabbit Lake, as described in the proposal, represents Cameco s share of the Cigar Lake ore. Currently, all operations at Cigar Lake, McClean Lake and Rabbit Lake developments have received environmental assessment approvals and are regulated under approvals, permits and licences issued by the Ministry. Submission of the January 2005 proposal satisfied the requirements of section 16(1) of the Act that the Minister be notified of any intent to make a change in an approved development. Application of The Environmental Assessment Act The January 2005 Rabbit Lake Project represented a change to each of the Cigar Lake, McClean Lake and Rabbit Lake developments that did not conform to the terms or conditions contained in the existing approvals, and any subsequent amendments, for each of the developments.... 2

2 Page 2 Under section 16(2) of the Act, once notice of a proposed change to an existing approval has been received, a ministerial decision is required. This decision determines the scope of the environmental assessment required to review the proposed change. Ministerial decision options under section 16(2) of the Act are: (a) approve the proposed change and impose any terms and conditions that are considered advisable; (b) refuse to approve the change in the development; or (c) direct the proponent to seek approval for the proposed change in the manner prescribed in sections 9 to 15 of the Act. The Ministry s Environmental Assessment Branch, with the assistance of the Saskatchewan Environmental Assessment Review Panel, conducted a technical review of the January 2005 Rabbit Lake Project proposal. This review was given to me for my use in making my decision under section 16(2) of the Act. In May 2005, based on my review of the issues raised by the proposed Rabbit Lake Project, I directed Cameco and AREVA to seek approval for the Rabbit Lake Project pursuant to section 16(2)(c) of the Act. Based on the comments from the technical review of the proposal, the Environmental Assessment Branch prepared project-specific guidelines to assist Cameco and AREVA with the conduct of the environmental impact assessment and the preparation of the environmental impact statement (EIS). The guidelines were provided in draft form to the public for review and comment from September 14 to October 14, 2005 before they were finalized. One public comment was received during the public review period. This comment did not identify any new or significant environmental issues related to the Rabbit Lake Project. Subsequently, Cameco and AREVA submitted an environmental impact statement, dated November 2006, and additional information, dated May 2007, for technical and public review. Environmental Impact Statement for the Rabbit Lake Project The environmental impact statement outlines the anticipated benefits and potential environmental concerns of the Rabbit Lake Project. The Rabbit Lake Project would create the necessary infrastructure in order to permit the final processing at the Rabbit Lake mill of a portion of the Cigar Lake ore being milled at the JEB mill at McClean Lake.... 3

3 Page 3 Processing this URS at Rabbit Lake would extend the life of the Rabbit Lake Operation and eliminate the need to establish a new uranium milling facility at Cigar Lake. This reduction in infrastructure provides better project economics for the Cigar Lake Project and maintains production flexibility in the northern Saskatchewan uranium mills. The EIS noted that this approach is consistent with the opinion of the Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan that recommended that, in order to minimize the number of locations affected by uranium milling operations, existing facilities should be used to mill ores from several mines rather than establish new mill facilities at new mines. The EIS stated that the URS project would allow the Rabbit Lake mill to return to a full-time operating schedule in the short to medium term that would not only create more jobs in the medium term but also retain the existing skilled workforce that has an effective workplace safety culture. The EIS also stated that, by increasing the life of the Rabbit Lake operation, the URS would allow the positive economic, employment and business opportunities generated by the Rabbit Lake Operation to continue to the benefit of the province. Operational activities at McClean Lake related to the Rabbit Lake Project would consist of pumping URS from the existing JEB mill circuit into new holding tanks and periodically transferring the solution from these tanks to truck-mounted containers for transport to Rabbit Lake along a new haul road. The URS would be transported from McClean Lake to Rabbit Lake in special containers by trucks over a new, direct haul road between the two sites. The road, which crosses Collins Creek, has a total length of 23 km. From McClean Lake to Collins Creek the route would utilize 12 km. of existing haul road on the McClean Lake site and then require 6.5 km. of new construction that would follow existing exploration trails. A clear-span concrete bridge would be constructed to cross Collins Creek. From Collins Creek to Rabbit Lake 4.5 km. of new construction would be required. The Rabbit Lake Project would require the Rabbit Lake Operation to return to a full-time operating schedule as well as requiring changes to the Rabbit Lake infrastructure and operating strategy. Changes to the Rabbit Lake mill would include the construction of a receiving facility to unload the URS from the trucks, changes to the leach circuit, construction of a new storage tank and sand filter clarification circuit and an increase in the dryer circuit capacity to a 6.5 million kg. per year uranium production rate.... 4

4 Page 4 Milling of the URS at Rabbit Lake would occur in two phases: an initial co-milling phase when the solution is co-milled with ore from the existing Eagle Point mine at Rabbit Lake and a second phase when only URS would be milled. The two milling phases would result in two types of mill tailings being generated that would be deposited in the Rabbit Lake in-pit tailings management facility. The Rabbit Lake Project would require the tailings storage capacity of the tailings facility to be increased. The increase in capacity would be achieved by two means: firstly by increasing the final tailings elevation and laterally expanding the tailings facility, and secondly by actively thawing frozen layers of tailings to increase the rate of tailings consolidation. The EIS also outlined the implications of the Rabbit Lake Project for air and water emissions at Rabbit Lake, waste rock management at Rabbit Lake, decommissioning at McClean Lake and Rabbit Lake, including the haul road, environmental monitoring and regional and cumulative effects. The EIS stated that the Rabbit Lake Project would have little impact on the McClean Lake Operation and would not require any changes to the current McClean Lake environmental monitoring or follow-up programs. The Rabbit Lake Project would require a minor update to the current McClean Lake decommissioning plan to incorporate the new URS load-out facility in the JEB mill. The EIS stated that the Rabbit Lake Project would have little effect on the overall decommissioning plan for Rabbit Lake other than the delay of decommissioning of some facilities as a consequence of the project extending the life of the Rabbit Lake Operation. The EIS described significant improvements to the decommissioning plans for the Rabbit Lake basin that are intended to minimize the overall impacts of existing and future tailings and waste rock in the Link Lake watershed. The improvements include relocating more material to the expanded Rabbit Lake tailings facility and covering above-ground waste piles. Environmental Assessment of the Rabbit Lake Project Technical Review The technical review of the EIS for the Rabbit Lake Project by provincial officials did not identify any significant environmental or technical issues that would require the public review of the EIS for the project to be delayed until the issues were resolved.... 5

5 Page 5 The technical review did identify a number of issues related to potential environmental impacts and environmental management that required clarification. Cameco and AREVA were requested to comment on these issues that included: metals concentrations in the URS, grade and volume of low-grade uranium ore stockpiles at Rabbit Lake and implications for decommissioning, geochemical characteristics of the Rabbit Lake tailings, radon monitoring at Rabbit Lake, lake water quality monitoring, groundwater flows into the Rabbit Lake tailings facility, effluent discharge to Horseshoe Creek, haul road construction, standards, safety and maintenance, spill management, groundwater monitoring associated with the Rabbit Lake tailings facility, commitments related to maximizing benefits to local residents and businesses, trapper compensation, and access to the haul road. Other comments on the EIS related to relatively minor points. Clarification of these points was requested to improve the quality and accuracy of the EIS and add to its acceptability for public review. Comments from some agencies advised Cameco and AREVA of regulatory requirements under various acts and regulations that would have to be met if the URS project receives environmental assessment approval. The responses to these issues provided by Cameco and AREVA were considered to be acceptable by provincial technical reviewers. As a consequence the EIS was considered technically acceptable to proceed to public review. Based on the comments from the technical review of the EIS, the Environmental Assessment Branch prepared Technical Review Comments. The Technical Review Comments and the EIS were provided to the public for review and comment from February 27 to March 28, One public comment was received during the public review period. This comment did not identify any new or significant environmental issues related to the Rabbit Lake Project. Environmental Issues Cigar Lake No environmental or technical changes would be required at Cigar Lake as a consequence of the Rabbit Lake Project.... 6

6 Page 6 An administrative amendment to the Cigar Lake environmental assessment approval would be required to identify that the final processing of a portion of the Cigar Lake ore would occur at Rabbit Lake. McClean Lake The EIS did not identify any significant technical issues that would occur at McClean Lake as a consequence of the implementation of the Rabbit Lake Project. With the exception of the mill modifications required to develop the load-out facility and the implications of the removal of the URS volume from the JEB mill circuit, all activities at McClean Lake previously have been subject to an environmental impact assessment. The analysis of the predicted impacts of the changes to McClean Lake as a consequence of the Rabbit Lake Project concluded that the impacts would fall within the scope of impacts predicted by previous environmental impact assessments of the McClean Lake Operation. Haul Road The potential environmental impacts associated with the haul road construction between McClean Lake and Rabbit Lake would be mitigated by the proposed use of existing haul roads and exploration trails. New road construction would be limited to 4.5 km. The use of a precast, concrete, clear-span bridge where the haul road crosses Collins Creek would avoid potential impact on fish or navigation. Biological surveys conducted along the haul road alignment did not identify any sensitive plant species or rare and endangered wildlife species and the potential impacts to wildlife were considered negligible. The potential for collisions between trucks and wildlife was considered minimal as a consequence of the limited number of daily haul trips between McClean Lake and Rabbit Lake (three to six) and the restricted truck speeds. The URS would be transported from McClean Lake to Rabbit Lake in containers similar to those used to transport uranium ore slurry from the McArthur River mine to the Key Lake mill. The containers would be subjected to drop tests to ensure their integrity in case of accidents. Potential safety issues related to the transportation of the URS by haul trucks, e.g., accidents, spills, would be incorporated into existing emergency and spill response plans for the McClean Lake and Rabbit Lake Operations.... 7

7 Page 7 Public access to the haul road through the surface lease areas of the McClean Lake and Rabbit Lake Operations would be restricted except for a trapper whose trapline would be crossed by the haul road. The portion of the haul road between the surface lease areas is not on surface lease lands and access to the haul road would not be controlled Cameco or AREVA. Access to the off-lease portion of the haul road through the surface leases by other mineral and surface rights holders would be considered on a case-by-case basis by Cameco and AREVA. Rabbit Lake The Rabbit Lake Project would require the Rabbit Lake mill to return to a full-time operating schedule. The EIS identified that the potential environmental impacts of the modifications to the Rabbit Lake mill and the full-time schedule required by the URS project would be managed by the current environmental management systems already in place for the environmental and safety performance of the mill. All of the changes to the Rabbit Lake Operation required by the implementation of the project would be confined to the existing Rabbit Lake surface lease area that previously has been disturbed by uranium mining and milling activities. The Rabbit Lake Project would result in additional exhaust ventilation from the URS receiving facilities at the mill, increased dryer emissions, and inert dust and fuel combustion effects resulting from increased truck traffic. The EIS stated that these effects are not anticipated to exceed current air quality standards at Rabbit Lake. The EIS described the current liquid effluent management procedures, including monitoring, treatment, and release to the receiving environment, at the Rabbit Lake site and discusses potential alterations to these procedures as a consequence of the project. During operations treated water from the Rabbit Lake water treatment plant is released to the Horseshoe Creek watershed that drains to Wollaston Lake. The treated water includes water from the Eagle Point underground mine, either used in the mill or treated directly, water from the Rabbit Lake tailings facility, and seepage water from the B-Zone and D-Zone open pits and the B-Zone waste rock pile. The Link Lake watershed, that drains intermittently to Wollaston Lake, would receive groundwater flows from the Rabbit Lake basin during the postdecommissioning phase of the Rabbit Lake Operation. These groundwater flows would include waters from the Rabbit Lake tailings facility and waters affected by contaminated sediments in Upper Link Lake that originated from the initial mining of the Rabbit Lake ore deposit.... 8

8 Page 8 The EIS identified that, while the Rabbit Lake Project would result in higher levels of arsenic and nickel in the contaminated water going to the water treatment plant from the mill, no significant changes would be required to the water treatment system to maintain current effluent quality standards. The EIS also identified that, as a result of other ongoing investigations to improve the quality of treated effluent, improvements to the water treatment system are planned. These improvements include modification to the neutralization and clarification circuits in the mill to enhance molybdenum and selenium removal and a membrane technology plant. The EIS concluded that the Rabbit Lake Project would not result in significant adverse environmental effects on the Horseshoe Creek watershed, the Link Lake watershed, or Wollaston Lake. The EIS stated that, based on proposed tailings volumes and consolidation analyses, an expansion of the tailings storage capacity of the Rabbit Lake in-pit tailings management facility would be required to accommodate the Rabbit Lake Project. Currently the technical performance of tailings facility is meeting or exceeding the originally predicted performance levels despite some frozen layers within the tailings mass. Based on current tailings consolidation behaviour the EIS estimated that the hydraulic conductivity of the consolidated tailings would be below design values within a few years after final tailings deposition. The performance levels for the tailings facility were set to ensure, during operations, the physical containment of tailings solids and the full containment of tailings supernatant and pore-water and, in the post-decommissioning phase, the minimization of contaminant loading to the downstream environment. These performance levels also were set ensure that no significant adverse impact to the environment would result from the operation of the tailings facility. As noted, the Rabbit Lake Project would require an expansion of the tailings facility. The increase in capacity would be achieved by increasing the final tailings elevation, laterally expanding the tailings facility, and actively thawing frozen layers of tailings to increase the rate of tailings consolidation. The EIS stated that, for the project, tailings management and waste rock management would be incorporated into an integrated management strategy. Using this strategy waste rock that is currently in surface stockpiles would be used in the construction of the lateral expansion of the existing Rabbit Lake tailings facility. This would represent an improvement to the current Rabbit Lake decommissioning plan and reduce the long-term environmental impact from existing waste rock and mineralized waste by relocating more of this material to the tailings facility. The EIS concluded that, while the changes to the tailings facility required by the Rabbit Lake Project would result in elevated levels of some metal contaminants entering groundwater flows from the tailings facility, these levels would not result in a significant adverse impact on the environment.... 9

9 Page 9 Cumulative Effects Currently two programs monitor potential cumulative effects from uranium mining and milling operations in northern Saskatchewan. These are the Cumulative Effects Monitoring Program established by the Ministry of Environment and the Canadian Nuclear Safety Commission and the environmental monitoring program administered by the Athabasca Working Group that was established by an agreement between the uranium mining companies and northern communities. The EIS assessed the potential cumulative effects of the McClean Lake Operation and the Rabbit Lake Operation in combination with other activities in the area. No significant adverse effects on animals or people from the combined emissions of the McClean Lake or Rabbit Lake operations were predicted. The EIS stated that the evaluations of the monitoring data do not suggest any cumulative effects in the vicinity of Athabasca communities that can be directly linked to emissions from operational uranium mining and milling facilities. Natural Resource Use The EIS reported the results of ecological risk assessments and the potential impacts of the URS project on natural resource use. The analyses showed that the project would have no significant effects on aquatic or terrestrial species in the area and that no effects on the availability of these resources for traditional or domestic use by Aboriginal people were expected. One trap line covers the area between Points North Landing and Collins Creek. The Impact Management Agreement sets out a claims process to address effects on local resource harvesting should they occur. To date, no claims have been filed. Environmental Regulation at McClean Lake and Rabbit Lake Operations The potential environmental impacts identified in the EIS, and any minor concerns noted during the technical review, would be addressed in detail by provincial licensing and regulatory procedures. Saskatchewan Ministry of Environment, under the Mineral Industry Environmental Protection Regulations, 1996, and other legislation, regulates all aspects of the operations at mine sites. Currently, operating approvals are in place regulating the Cigar Lake, McClean Lake, and Rabbit Lake Operations

10 Page 10 These regulatory approvals address liquid effluent management procedures and establish liquid effluent discharge limits for treated water at mine sites. Limits are included in the Operating Approvals issued by the Ministry to ensure that the quality and quantity of treated water released will not affect the aquatic habitats and fisheries in receiving watersheds. The points of discharge and timing of releases to the receiving environment are carefully regulated. Specific details of any changes to the current operating approvals at McClean Lake and Rabbit Lake that would be required by the Rabbit Lake Project would be determined in consultation with the Industrial, Uranium and Hardrock Mining Unit, Saskatchewan Ministry of Environment, during regulatory licensing. Occupational Health and Safety The Cigar Lake, McClean Lake, and Rabbit Lake Operations have been previously approved and all activities at these operations have to meet current provincial standards for conventional and radiological occupational health and safety. These standards are cited in the Occupational Health and Safety Act, 1993, the Occupational Health and Safety Regulations, 1996, the Radiation Health and Safety Act, 1985, the Radiation Health and Safety Regulations, 1993, and in the Saskatchewan Mines Regulations, All aspects of the Rabbit Lake Project would have to meet these same standards. The proposed changes to these operations required by the Rabbit Lake Project would have only minor impact on the health and safety of workers and would be managed by the continued application of the occupational health and safety programs already in place at the Cigar Lake, McClean Lake, and Rabbit Lake Operations. Public Involvement and Socio-Economic Issues The Ministry is satisfied that regional residents and organizations were notified about the Rabbit Lake Project and were provided with the opportunity to be involved with the environmental assessment process. Cameco and AREVA conducted consultation activities under ongoing public information programs to keep the public informed about current uranium mining activities and new projects, to identify public issues or concerns, and to inform the public about environmental assessment and regulatory decisions affecting their projects

11 Page 11 As described in the EIS the public consultation programs conducted by Cameco and AREVA was composed of four components: (1) Industry Consultation with Northern Communities: These programs focused on resident communities in northern Saskatchewan. These communities included Black Lake Denesuline First Nation, Fond du Lac Denesuline First Nation, Hatchet Lake Denesuline First Nation, Northern Settlement of Camsell Portage, Northern Hamlet of Stony Rapids, Northern Settlement of Uranium City, Northern Settlement of Wollaston Lake, Ile a la Crosse, La Loche, Patuanuk, Beauval, Pinehouse, La Ronge and Buffalo Narrows. Meetings were held in these communities and included community meeting presentations, school presentations, distribution of brochures and table-top displays. Materials in print format included, articles in the Opportunity North magazine, news releases, corporate newsletters, posters and handbills, advertisements in newspapers and corporate sustainability reports. Radio coverage also was used to advertise meetings and to provide a forum for interviews on special topics and for answering community questions. (2) Technical Project Review Workshops: Technical workshops were held in Stony Rapids and at the Rabbit Lake Operation on March 6 and 7, These workshops discussed the major components of the URS project. Twenty-four individuals from the Athabasca region participated. Participants included youth, elders, community leaders, Athabasca Working Group members and Athabasca Environmental Quality Committee members. (3) Consultation on Specific Technical Issues: This involved discussion of specific technical issues with groups set up to facilitate liaison between the communities and industry, particularly the Athabasca Working Group in the Athabasca region and the Athabasca Environmental Quality Committee of the Northern Mines Monitoring Secretariat. The Athabasca Working Group Coordinator is employed by the uranium mining industry and is available to answer or re-direct concerns from community members regarding uranium developments. The Environmental Quality Committee was set up to provide a formal opportunity for industry and government to discuss technical aspects of the uranium mining industry with northern communities and their representatives. The Environmental Quality Committee reviewed the Valued Ecosystem Components relevant to the environmental impact assessment studies for the Rabbit Lake Project on February 9,

12 Page 12 (4) Consultation with Other Stakeholders: Cameco and AREVA also communicated with other stakeholders in northern and southern Saskatchewan, including non-government organizations and interest groups, regional organizations and staff of relevant government departments. Information was provided through meetings, newsletters, brochures, web-based information and presentations. Public meetings were held in Saskatoon and Prince Albert. Formal opportunities for public participation also were provided by the public reviews of the draft project-specific guidelines and the environmental impact statement that form part of the Saskatchewan environmental impact assessment process and the public review components of the federal environmental assessment review process. Several agencies commented that the listing of the public involvement programs was substantial and provided opportunity for local northern residents to be involved. The McClean Operation and the Rabbit Lake Operation currently have comprehensive protection programs for occupational health and safety and radiation protection. Given the results of current on-site and off-site programs monitoring potential environmental contaminants and the remote locations of the McClean Lake and Rabbit Lake sites, the technical review of the EIS did not foresee that the Rabbit Lake Project would have any negative impact on public health and safety. The Rabbit Lake Project would increase the life of the Rabbit Lake Operation and allow the positive economic, employment and business opportunities generated by the Rabbit Lake Operation to continue to the benefit of the province. The project would allow the Rabbit Lake mill to return to a full-time operating schedule in the short to medium term that would not only create more jobs in the medium term but also retain the existing skilled workforce that has an effective workplace safety culture. At peak activity, construction at McClean Lake related to the Rabbit Lake Project would generate about 30 jobs, mainly for skilled and semi-skilled workers. The $4 million construction contract would be open to bid by northern contractors or joint ventures. Operation of the load-out facility would need an additional 4 jobs, ideally from the Athabasca region. Road construction would require seven months over a two-year period with a peak employment of 75 jobs, mainly skilled and semi-skilled workers. The construction contract worth $16 million would be let preferably to a northern contractor. Transportation of the URS would be by contractual or employment arrangements

13 Page 13 Construction at Rabbit Lake related to the Rabbit Lake Project would take place over two years and result in about 50 jobs for skilled and semi-skilled workers. The EIS stated that construction contracts are estimated to be about $40 million and that they were likely to be selected through an open-bid process, with preference for Athabasca region contractors or joint ventures. The changes to the Rabbit Lake Operation would generate an additional 65 jobs, mainly in mill operations with other positions in administration, mining and services. The EIS noted that this work is part of a long-term estimated $100 million upgrade to Rabbit Lake to create a sustainable regional milling center for future Athabasca region ore deposits. Cameco and AREVA have signed Human Resource Development Agreements with the Government of Saskatchewan respectively for the Rabbit Lake and McClean Lake Operations. Both Cameco and AREVA have signed the 1999 Impact Management Agreement with six of the seven communities in the Athabasca region. These agreements set out the framework and details of the commitments and specific measures aimed at maximizing employment and business participation of residents of northern Saskatchewan in uranium mining. Multiple programs are identified that assist in the recruiting, training and retention of a northern workforce. Reviewers have noted that Cameco and AREVA, to date, have done a good job in terms of maximizing benefits for northern residents and businesses. Summary of Environmental Assessment It is the opinion of ministry officials that the Rabbit Lake Project could proceed without significant impact to worker health and safety or to the environment. Provincial reviewers are satisfied that Cameco and AREVA have addressed the pertinent environmental issues associated with the project and that the project does not pose any new or significant environmental risk. Current regulatory approvals for the Cigar Lake, McClean Lake and Rabbit Lake developments, pursuant to the Mineral Industry Environmental Protection Regulations, 1996, include monitoring and conceptual decommissioning and reclamation plans that are updated on a regular basis or when site operations are modified substantially. Current operating approvals also address liquid effluent management procedures, establish liquid effluent discharge limits for treated water, and specify monitoring procedures. Limits are included in the Operating Approvals issued by the ministry to ensure that the quality and quantity of treated water released to the environment will not cause significant adverse environmental effects on the aquatic habitats and fisheries in receiving watersheds. The points of discharge and timing of releases to the receiving environment are carefully regulated

14 Page 14 Specific details of the required monitoring programs for the Rabbit Lake Project would be determined in consultation with the Industrial, Uranium and Hardrock Mining Unit, Saskatchewan Ministry of Environment, during regulatory licensing. Current operating approvals also address detailed plans for decommissioning, reclamation, and abandonment of the Cigar Lake, McClean Lake and Rabbit Lake developments. These plans provide the basis for the calculation of financial assurances to ensure that Cigar Lake, McClean Lake and Rabbit Lake developments can be decommissioned and reclaimed without cost to the province. Specific details of changes to the current plans for decommissioning, reclamation, and abandonment of the Cigar Lake, McClean Lake and Rabbit Lake developments necessary to incorporate the Rabbit Lake Project, would be developed in consultation with the Industrial, Uranium and Hardrock Mining Unit, Saskatchewan Ministry of Environment, during regulatory licensing. The Cigar Lake, McClean Lake and Rabbit Lake developments have comprehensive programs in place for occupational health and safety and radiation protection. Given the results of current on-site and off-site programs monitoring potential environmental contaminants and the remote location of the Cigar Lake, McClean Lake and Rabbit Lake developments, the review did not foresee any negative impact on worker health and safety or public health. Cameco and AREVA held public information/consultation sessions in northern communities to discuss the Rabbit Lake Project. These public involvement activities also addressed the cumulative effects from other developments, mitigative measures for adverse effects, concerns raised about effects on the environment and people, and employment and business opportunities. The Environmental Quality Committee was consulted on traditional knowledge and land use during the identification of valued ecosystem components. Provincial reviewers agreed that AREVA, to date, has done a good job in terms of maximizing benefits for northern residents and businesses. The ministry and review agencies are satisfied that the mitigation and environmental protection measures outlined in the proposal are consistent with public expectations that a proponent and the government ensure all reasonable steps are taken to ensure environmental protection

15 Page 15 Federal Provincial Coordination of Environmental Assessment In keeping with the Canada-Saskatchewan Agreement on Environmental Assessment Cooperation, 2005, federal and provincial review processes were coordinated throughout the environmental assessment. Regulatory processes of the federal and provincial governments issuing operational approvals, permits and licences for the Rabbit Lake Project also will be coordinated. Decision to Approve the Rabbit Lake Project I have concluded that the Rabbit Lake Project is environmentally acceptable and will not pose a significant risk to the environment in the long term. I also have concluded that any adverse environmental effects associated with the Rabbit Lake Project can be successfully mitigated or minimized. I am satisfied that the environmental effects are acceptable given the benefits that will result from the project. The issues raised are primarily technical and site-specific and any potentially adverse environmental effects can be managed successfully under the terms and conditions of the current approvals for the Cigar Lake, McClean Lake and Rabbit Lake developments, the terms and conditions attached to this approval, and the terms and conditions forming parts of the permits, licences, and approvals required by The Mineral Industry Environmental Protection Regulations, 1996, and other provincial legislation, for the Rabbit Lake Project. Based on the public reviews of the project-specific guidelines, the environmental impact statement and the Technical Review Comments, I have concluded that further public review of the Rabbit Lake Project under the Act is not necessary. My decision to approve the Rabbit Lake Project is based on the technical and public reviews of the environmental impact statement, Cameco and AREVA s commitments as documented in the environmental impact statement, on my ability as the Minister of Environment to impose specific conditions at this time, and on the knowledge that any additional environmental protection requirements can be imposed through terms and conditions forming parts of the permits, licences, and approvals required by provincial legislation for the Rabbit Lake Project. My decision amends the current ministerial approvals for the Cigar Lake, McClean Lake and Rabbit Lake developments and approves the changes in these developments required for the management of the Rabbit Lake Project

16 Page 16 With the exception of amendments that are necessary to allow the changes to the Cigar Lake, McClean Lake and Rabbit Lake developments to occur, this approval does not alter the terms and conditions attached to the current ministerial approvals, as amended, issued to the Cigar Lake, McClean Lake and Rabbit Lake developments. Those terms and conditions were designed to evaluate environmental protection options and to minimize or eliminate potential adverse environmental effects associated with the Cigar Lake, McClean Lake and Rabbit Lake developments and are still in effect. I make this decision knowing that, on the 19 June, 2008, the Canadian Nuclear Safety Commission released a screening decision, consistent with section 20 of the Canadian Environmental Assessment Act, approving a Commission staff recommendation that the Rabbit Lake Project is not likely to cause significant adverse environmental effects, taking into account proposed mitigation measures, and allowing Commission staff to proceed under the Nuclear Safety and Control Act with the consideration of regulatory applications from Cameco and AREVA for the Rabbit Lake Project. My decision also was made with the knowledge that other legislation is in place to ensure that all aspects of the project will be regulated. Dated at Regina, Saskatchewan, this 30th day of July, 2008 Original signed by: Nancy Heppner Minister of Environment