VIA . March 24, 2017

Transcription

1 March 24, 2017 VIA Mr. Marc Leblanc Commission Secretary Canadian Nuclear Safety Commission P.O. Box 1046, Station B 280 Slater Street Ottawa, ON Canada K1P5S9 Dear Mr. Leblanc: Re: Submission for June 7&8, 2017 Public Hearing Renewal of the McClean Lake Operating Licence UMOL-MINEMILL-McCLEAN.01/2017 On August 22, 2016, (AREVA) submitted a request to renew the McClean Lake Operating Licence UMOL-MINEMILL-McCLEAN.01/2017, approving the activities currently authorized for an additional 12-year term. Attached is a copy of AREVA s written Commission Member Document and Notice of Participation for the June 7 & 8, 2017 public hearing. Sincerely, Dale Huffman VP Health, Safety, Environment & Regulatory Relations cc: Bob Lojk (CNSC) Salman Akhter (CNSC) UMMD Distribution ARC Distribution Attachments: Notice of Participation Written Submission

2 Notice of Participation in CNSC Public Hearing As per the CNSC Rules of Procedure, this is to provide notice that will appear to make an oral presentation at the CNSC public hearing on the consideration of the request to renew the McClean Lake Operating licence, to be held June 7 & 8, 2017 in La Ronge, Saskatchewan. 1. Applicant Information PO Box th Street West Saskatoon, Saskatchewan S7L 3X5 Phone: (Dale Huffman) dale.huffman@areva.com 2. will appear at the public hearing, with the following company representatives in attendance: Mr. Vincent Martin President and Chief Executive Officer Mr. Dale Huffman Vice President, Health, Safety, Environment and Regulatory Relations Mr. Eric Pacquet Vice President, Operations & Projects Mr. Glenn Lafleur Manager, Northern Affairs Mr. Vincent Laniece General Manager, Ms. Tammy Van Lambalgen Vice President, Corporate Affairs & General Counsel Ms. Tina Searcy Manager, Regulatory Relations Ms. Carolanne Inglis-McQuay Senior CSR Advisor Any correspondence or communication from the CNSC concerning the public hearing should be directed to Mr. Dale Huffman at the addresses provided in above in Section will be represented by company staff and will not be using an external counsel or agent. 4. will be providing a written submission (attached) and an oral submission for the public hearing (forthcoming). 5. The official language to be used by in the presentation will be English.

3 Date Submitted: March 24, 2017 One Day Public Hearing Scheduled for: June 7 & 8, 2017 : Regarding: Renewal of the McClean Lake Uranium Mine Operating Licence Submitted by:

4 Table of Contents Executive Summary... v Introduction Background Overview of the JEB Site Sue and Midwest Sites Summary of Application Licence Renewal Request Licensing History Environmental Assessment History Business Plan McClean Lake Mill Production Forecast Mining Production Forecast Improvement Plans and Significant Activities Relocation of Contaminated Landfill Upgrades to the Sue Water Treatment Plant JEB TMF Expansion SABRE Project Cigar Lake Mine Potentially Reactive Waste Rock Selenium Adaptive Management Plan Sulphur Dioxide Mitigation Potential Future Mining and Milling Long term plan Safety and Control Areas Management System Relevance and Management Past Performance Future Plans Challenges Requests Human Performance Management Relevance and Management Past Performance Future Plans Challenges Requests Page i Table of Contents

5 3.3 Operating Performance Relevance and Management Past Performance Future Plans Challenges Requests Safety Analysis Relevance and Management Past Performance Future Plans Challenges Requests Physical Design Relevance and Management Past Performance Future Plans Challenges Requests Fitness for Service Relevance and Management Past Performance Future Plans Challenges Requests Radiation Protection Relevance and Management Past Performance Future Plans Challenges Requests Conventional Health & Safety Relevance and Management Past Performance Future Plans Challenges Requests Environmental Protection Relevance and Management Past Performance Continual Improvement: Effluent Quality Monitoring: Ambient Air Quality Monitoring: Page ii Table of Contents

6 Groundwater monitoring: Reportable Releases of Hazardous Substances Future Plans Challenges Requests Emergency Management and Fire Protection Relevance and Management Past Performance Future Plans Challenges Requests Waste Management Relevance and Management Preliminary Decommissioning Plan Past Performance Future Plans Challenges Requests Security Relevance and Management Past Performance Future Plans Challenges Requests Safeguards and Non-Proliferation Relevance and Management Past Performance Future Plans Challenges Requests Packaging and Transport Relevance and Management Past Performance Future Plans Challenges Requests Other Matters of Regulatory Interest AREVA s Public Information Program and Aboriginal Engagement Activities Aboriginal Engagement Activities Public Interest Survey Public Support Page iii Table of Contents

7 4.3 Cost Recovery Financial Guarantees Conclusions References List of Acronyms List of Tables Table 1-1: Environmental Assessment History Table 3-1: Total number of FTE workers, LTI, severity rate and frequency rate, Table 4-1: Public Engagement Activities Conducted by AREVA for the MLO Renewal List of Figures Figure 1-1: Location of the in Northern Saskatchewan Figure 1-2: General Areas Figure 1-3: Site Layout Figure 1-4: McClean Lake Mill (24 Mlbs per year capacity) Figure 1-5: McClean Lake Mill (24 Mlbs/year) with JEB TMF in Background Figure 2-1: Long Term Plan* Figure 3-1: Management Team Figure 3-2: McClean Lake Site: Total Effective Dose (Gamma, RnP, LLRD) Figure 3-3: Uranium in JEB WTP Effluent Figure 3-4: Arsenic in JEB WTP Effluent Figure 3-5: Molybdenum in JEB WTP Effluent Figure 3-6: Nickel in JEB WTP Effluent Figure 3-7: Selenium in JEB WTP Effluent Figure 3-8: Radium-226 in JEB WTP Effluent Figure 3-9: Average Air Quality on McClean Lake Mill Terrace Figure 3-10: Average Annual SO 2 Concentrations in the Ambient Air Figure 3-11: Reportable Spills of Hazardous Substances (2009 through June 2016) Figure 3-12: Ore Slurry Truck: Tractor, Trailer and Containers Figure 4-1: Northern Saskatchewan Administrative District Figure 4-2: Public Support Page iv Table of Contents

8 Executive Summary The is a uranium mining and milling facility located in the Athabasca Basin of northern Saskatchewan. (AREVA) operates the in accordance with Licence UMOL-MINEMILL-McCLEAN.00/2017 issued by the Canadian Nuclear Safety Commission (CNSC) on July 1, 2009 (Licence). The Licence is for an eight-year term expiring on June 30, In August 2016, AREVA applied to the CNSC to renew the operating Licence to continue authorized operations, which include: the operation and modification of a nuclear facility for the mining of uranium and the production of uranium concentrate (U 3 O 8 ) at the ; to mine a nuclear substance (uranium ore); produce a uranium concentrate; and import, possess, use, store, transfer and dispose of nuclear substances and radiation devices. AREVA is not proposing any new activities and is requesting that the Licence be issued for a 12-year term. AREVA is also requesting acceptance of the revised financial guarantee for the decommissioning of the, for C$107,241,000, as described in the revised Preliminary Decommissioning Plan [1]. Since the issuance of the Licence in 2009, the McClean Lake Mill transitioned into a temporary (four year) cessation of milling, underwent a mill construction upgrade to enable production of 10,909,090 kilograms (24 million pounds) U 3 O 8 per year, accomplished a successful restart, commissioning and ramp-up of production with the receipt of high grade ore slurry shipments from the Cigar Lake Mine. The JEB Tailings Management Facility (TMF) also underwent works to optimize capacity. This Commission Member Document (CMD) describes the s performance over the current Licence term for each of the Safety and Control Areas (SCAs) as outlined in the Licence Conditions Handbook (LCH). AREVA commits to alignment with Canadian Standards Association (CSA) standards and CNSC Regulatory Documents (REGDOCs). AREVA submits that it is a qualified operator who conducts its operations in a manner consistent with the requirements of the Nuclear Safety Control Act, its regulations and other legislative requirements. In particular, AREVA submits that it is qualified to continue to operate the and perform the activities authorized by the Licence and that the necessary measures are in place to ensure AREVA continues to conduct its operations in a manner: to limit the risks to the health and safety of workers and the public; to limit the risks to the environment; to limit the risks to national security; and consistent with Canada s international obligations. Page v Executive Summary

9 1 Introduction 1.1 Background The is a joint venture between (AREVA), Denison Mines Inc. and Oversees Uranium Resources Development (OURD) Canada Co., Ltd, and is operated by AREVA. AREVA is a Canadian company, headquartered in Saskatoon, Saskatchewan. AREVA is a subsidiary of the multinational AREVA group headquartered in France. The AREVA group provides its customer with high added-value solutions, products, technologies and services in mining, uranium chemistry, uranium enrichment, used fuel recycling, logistics, dismantling, and fuel cycle engineering. AREVA is organized into two main activities, New AREVA (NA) and AREVA NP (NP). In accordance with the guidelines for the reorganization of the nuclear industry set out by the French State, AREVA is effecting a strategic refocusing on its nuclear fuel cycle business. AREVA Resources Canada is part of New AREVA, which includes all of the fuel cycle activities and related central departments. New AREVA, refocused on the production and recycling of nuclear materials and waste management, is developing its activities in mining, uranium chemistry (conversion and enrichment), used fuel recycling, logistics, dismantling and fuel cycle engineering. The is a uranium mine and mill facility located in northern Saskatchewan. As shown in Figure 1-1, the is located approximately 750 kilometres north of Saskatoon, in the Athabasca Basin region of Saskatchewan near the northern most limit of the provincial highway #905. In 1994, the Atomic Energy Control Board (AECB) (predecessor to the Canadian Nuclear Safety Commission) (CNSC) issued COGEMA (predecessor to AREVA) a Licence for the McClean Lake Operation. This Licence has since been subject to several renewals and amendments. On July 1, 2009, licence UMOL-MINEMILL-McCLEAN.00/2017 was issued for an eight-year term expiring on June 30, 2017 (Licence). The Licence was amended in 2012 to increase the annual production limit from 3,629,300 kilograms (kg) (8 million pounds (Mlbs)) U 3 O 8 to 5,909,090 kg (13 Mlbs) U 3 O 8, approve the operation of the high grade ore slurry receiving circuits, and adopt the Licence Condition Handbook (LCH) framework. The McClean Lake Mill was designed and constructed for the processing of high-grade uranium ore slurry from the Cigar Lake Mine. Construction of the McClean Lake Mill began in It was initially constructed for an annual production rate of 8 Mlbs U 3 O 8 and at that time was licensed for an annual production of 2,722,000 kg (6 Mlbs) U 3 O 8, with the anticipation of future expansions to milling circuits. Production capacity was subsequently authorized to 8 Mlbs U 3 O 8 per year. Page 1-1 Section 1: Introduction

10 In 1999, the McClean Lake Mill was commissioned with run-of-mine uranium ore from JEB and Sue ore bodies through a conventional grinding circuit. Run-of-mine ore processing continued from 1999 through 2010 with average annual ore grades ranging from 0.4% to 2.5% uranium, at annual production levels ranging from 680,000 (1.5 Mlbs) to 2,940,000 (6.5 Mlbs) U 3 O 8. The commenced construction of the Mill Expansion Project in 2005 [2]. This project included construction activities to modify the McClean Lake Mill for receipt and processing of high grade ore slurry from the Cigar Lake Mine and to expand the annual production capacity of the McClean Lake Mill to 13 Mlbs U 3 O 8. At that time, 100% of the ore slurry from the Cigar Lake Mine was planned to be transported to the McClean Lake Mill for initial processing, while the back-end processing and packaging was to be shared between the McClean Lake Mill and Cameco s Rabbit Lake Mill. In 2006, in the midst of the construction activities to expand the mill, an inflow occurred at the Cigar Lake Mine, which delayed the receipt of ore slurry. In 2007, temporary modifications were subsequently made to the McClean Lake Mill to process low grade ore and to increase the volume of ore feed through the Mill Optimization Project [3]. By 2009, the planned construction and commissioning activities associated with both the Mill Expansion Project and the Mill Optimization Project were complete, with the exception of the commissioning of the Slurry Receiving Circuit. In July 2010, with no further economic ore sources available, the McClean Lake Mill transitioned into a temporary cessation of milling. The McClean Lake Mill underwent a safe and systematic shut-down, cleanout and flushing of each circuit. The took advantage of the shut-down period to install a new yellowcake packaging system; it was installed in 2013 and was ready to operate by March In November 2011, AREVA and its McClean Lake Joint Venture and Cigar Lake Joint Venture partners entered into an agreement to process and package 100% of the ore slurry from the Cigar Lake Mine at the McClean Lake Mill. The agreement required an upgrade of the McClean Lake Mill from its current annual back-end capacity of 13 Mlbs U 3 O 8 to 10,909,090 kg (24 Mlbs) U 3 O 8. The decision to process and package 100% of Cigar Lake ore at the McClean Lake Mill was a return to the milling concept initially assessed and approved in the 1995 Environmental Impact Statement (EIS) for the Cigar Lake Operation [4], and maintained in subsequent environmental assessments. As a result of the decision to process and package 100% of the ore slurry from the Cigar Lake Mine at the McClean Lake Mill, AREVA submitted its proposal to upgrade the existing McClean Lake Mill to allow for an annual production of rate of 24 Mlbs U 3 O 8. [5] In 2012, AREVA received approval from the CNSC Commission to operate the high-grade ore circuits and the Slurry Receiving Circuit, increase annual production to 13 Mlbs U 3 O 8 and process McArthur River ore [6]. It was at the 2012 proceedings before the Commission that the CNSC Staff presented and the CNSC Commission approved to adopt the LCH format, which now lists the authorized activities, including the annual production rate for the McClean Lake Mill. Subsequent to this Licence amendment, the McClean Lake Operation submitted a notification to the CNSC and an application to Saskatchewan Ministry of Environment (SMOE) to construct the Mill Upgrade Project, which would increase the mill s annual capacity to 24 Mlbs U 3 O 8 [5]. Evaluation of both project and process alternatives were presented in the application, together with corresponding risk analyses. In 2013, approval of the Mill Upgrade Project was included as an amendment to the s LCH [7]. The construction commenced in 2013 and the Mill Page 1-2 Section 1: Introduction

11 Upgrade Project was substantially completed in 2015, with the exception of the new Tailings Neutralization Circuit, which was completed in 2016 and commissioned with product in early In 2010, the CNSC approved [8] AREVA s request to conduct activities to ensure the assessed capacity of the JEB TMF would be realized. The activities were to ensure slope stability and pond water containment during the operation of the JEB TMF and involved sloping of existing till slopes and the construction of a bentonite amended liner. The project is entitled the JEB TMF Optimization Project [9], the first stage was conducted in , making slope improvements and placing a liner to 439 masl. The second stage will involve sloping improvements and placement of liner to 443 masl. Intermittent ore slurry shipments from Cigar Lake Mine commenced in March With consistent delivery of Cigar Lake ore slurry received through the Slurry Receiving Circuit since September 2014, AREVA accomplished a successful restart, commissioning and ramp-up of production at the McClean Lake Mill, as demonstrated in the Commissioning Report [10]. In 2016, the CNSC approved AREVA s request to increase annual production to 24 Mlbs U 3 O 8 [11]. Throughout 2016, the McClean Lake Mill demonstrated performance at monthly rates exceeding a rate equivalent to 18 Mlbs per year U 3 O 8, with ore grades up to 32% U. 1.2 Overview of the As shown in Figure 1-2, the consists of three general areas: the JEB site, the Sue site, and the Midwest site. Figure 1-3 shows the various facilities located at the. The JEB site is the location of the McClean Lake Mill and other ancillary facilities related to the milling operation such as the JEB Water Treatment Plant (WTP) and JEB TMF. The Sue site, connected to the McClean Lake Mill by a 12 km haul road, is the location of the majority of the previously mined deposits, the Sue WTP, and the Surface Access Borehole Resource Extraction (SABRE) Project area, which sits above the uranium deposits referred to as McClean Ore Pods. The Midwest site has undergone multiple environmental assessments for varying mining techniques; the latest environmental assessment for open pit development was approved federally and provincially in The Midwest site is currently connected to the by the Provincial highway #905 but once developed will be connected by a 17 km haul road and utility corridor. A further description of each of these main areas is provided below. Page 1-3 Section 1: Introduction

12 Figure 1-1: Location of the in Northern Saskatchewan Page 1-4 Section 1: Introduction

13 Figure 1-2: General Areas Page 1-5 Section 1: Introduction

14 Figure 1-3: Site Layout Page 1-6 Section 1: Introduction

15 1.2.1 JEB Site The McClean Lake Mill located at the JEB site was designed and constructed to process both uranium ore slurry and run-of-mine ore at grades ranging from less than 1% to 30% U. The McClean Lake Mill uses grinding, leaching and a solvent extraction recovery process to extract and concentrate the uranium from the ore. The potential environmental impacts of the have been assessed for a production rate of 12,247,000 kg (27 Mlbs) U 3 O 8 per year. The McClean Lake Mill was initially constructed to produce 8 Mlbs U 3 O 8 per year but was expanded from 2005 to 2007 to produce 13 Mlbs U 3 O 8 per year with the construction of the ore slurry receiving circuit. The McClean Lake Mill was further expanded from 2013 to 2016 to produce 24 Mlbs U 3 O 8 per year. Figure 1-4 provides an overview of the McClean Lake Mill expanded to produce 24 Mlbs U 3 O 8 per year. Figure 1-5 depicts the McClean Lake Mill following the expansion to 24 Mlbs U 3 O 8 per year and shows the JEB TMF in the background. Figure 1-4: McClean Lake Mill (24 Mlbs per year capacity) Page 1-7 Section 1: Introduction

16 Figure 1-5: McClean Lake Mill (24 Mlbs/year) with JEB TMF in Background Sue and Midwest Sites The other two main areas of the are the Sue and Midwest sites. The Sue site has been the primary mining area to date and contains the Sue deposits, the McClean deposits and the Caribou deposit. Open pit mining of the Sue C, Sue A, Sue E, and Sue B pits was completed using the conventional drill, blast, load and haul mining method. The remaining deposits in the Sue site are undergoing feasibility studies to determine the most suitable mining methods. The Sue site area is also the location of the SABRE Project, which is a developmental mining program evaluating the extraction of uranium mineralization from ore bodies using a hydraulic borehole (jet boring) mining method that is conducted from the surface. This developmental mining method continues to undergo evaluation to assess it as a viable alternative mining method. The Sue site main infrastructure includes the Sue WTP and the Sue Heavy Duty Maintenance Shop. Page 1-8 Section 1: Introduction

17 The Midwest site was the location of an underground test mine facility operated by the previous operator, Denison Mines Corp, in the 1980 s. AREVA became operator of the Midwest Project in 1993 when the site was in care and maintenance. In August 2012, the environmental assessment to mine Midwest as an open pit mine with the run-of-mine ore transported on a 17 km haul road to the McClean Lake Mill for processing was approved. Determining the most suitable mining method of the Midwest deposit is in progress and once a development decision is made, it is anticipated that the project will proceed to the licensing phase. 1.3 Summary of Application Licence Renewal Request On August 22, 2016 AREVA applied to the Commission Secretariat to renew the s operating Licence [12], which will expire on June 30, The renewal of the Licence provides AREVA the ability to continue operations authorized by the Licence, which include: the operation and modification of a nuclear facility for the mining of uranium and the production of uranium concentrate (U 3 O 8 ) at the McClean Lake Operation; to mine a nuclear substance (uranium ore); produce a uranium concentrate; and import, possess, use, store, transfer and dispose of nuclear substances and radiation devices. AREVA is not proposing new activities and is requesting that the Licence be issued for a 12-year term. AREVA is also requesting acceptance of the revised financial guarantee for the decommissioning of the McClean Lake Operation in the amount of C$107,241,000, as proposed in the revised Preliminary Decommissioning Plan [1] Licensing History In 1994, the AECB (CNSC predecessor) issued AREVA (then COGEMA) a Licence for the McClean Lake Operation, which has since received several renewals and amendments. On July 1, 2009, Licence UMOL- MINEMILL-McCLEAN.00/2017 was issued for an eight-year term expiring on June 30, 2017 (Licence); this Licence was amended in 2012 to increase the annual production from 8 Mlbs to 13 Mlbs U 3 O 8, approve the operation of the high grade ore slurry receiving circuits and adopt the LCH framework. The first LCH for the was issued in March Environmental Assessment History AREVA does not have any active projects in the environmental assessment (EA) process under the Canadian Environmental Assessment Act, 2012 and understands that licensing actions including this request to renew the Licence are subject to an EA under the Nuclear Safety Control Act. The environmental assessment history for the is provided in Table 1-1. Page 1-9 Section 1: Introduction

18 Table 1-1: Environmental Assessment History Project Environmental Assessment Subsequent Licensing Actions Aspect Relevant to the Project McClean Lake Operation McClean Lake EIS: 1991 *included Midwest as an underground development Joint Panel Approved: 1993 Subsequent assessment to confirm acceptability of JEB TMF (Cigar Lake Project 1995) 1995 Midwest EIS Addenda submitted: 1996 (March, May, October) and May 1997 Joint Panel Approved: 1997 Atomic Energy Control Board (AECB) and Provincial Approval to Construct and Operate the McClean Lake Mine and Mill Initial approval for the overall McClean Lake Project, which included the JEB Mill and the overall waste management system Midwest Project was rejected by the 1993 Joint Panel Subsequent approval for the JEB TMF facility 6 million lbs (licence) 1995 Midwest Project Adopted new mining method, jet-boring in frozen ground Cigar Lake Project Cigar Lake EIS: 1995 Joint Panel Approved: 1997 Canadian Nuclear Safety Commission (CNSC) and Provincial Approval to Construct Cigar Lake Mine (December 2004) CNSC and Provincial Approval to Expand the JEB Mill to Process Cigar Lake Ore (2005) Assessment and approval to process up to 24 million lbs (10.9 million kg) of U 3O 8 annually and of that, process 18 million pounds (8.2 million kg) U 3O 8 from Cigar Lake high grade ore slurry through the JEB Mill expansion (including deposition of tails to the JEB TMF) Assessment and approval of the activity of transporting high grade ore slurry to McClean Lake The transport and disposal of Cigar Lake waste rock in the McClean Lake Operation's Sue C/A pit 2001 Disposal of Cigar Lake Waste Rock EIS, Federal Screening Report Approved: 2003 Sue E Project Federal and Provincial Screening Approved: 2005 CNSC and Provincial Approval to Construct and Operate the SUE E Project (2005) Subsequent assessments demonstrate that the past, current and planned future activities at the continue to fall within the environmental effects envelope originally reviewed by the Joint Panel. These effects considered production levels from McClean Lake to be up to 24 million lbs (10.9 million kg) U 3O 8 through the JEB Mill, based on the processing of high grade ore. Receipt of 18 Mlbs from Cigar Lake, sending equivalent of 10 Mlbs to Rabbit Lake as Uranium Solution and processing 8 Mlbs of Cigar Lake ore through JEB Mill with remaining capacity for McClean Lake source ores Rabbit Lake Solution Processing Plant Screening Report Approved: Province August 2008 CNSC June 2008 Page 1-10 Section 1: Introduction

19 Project Environmental Assessment Subsequent Licensing Actions Aspect Relevant to the Project Midwest Project Project Description submitted 2005 Draft EIS 2007 and 2010 Final EIS 2011 Approved: Provincial and Federal August 2012 No development decision Midwest as an open pit Includes a mill expansion 27/16 million lbs base case 27/27 million lbs cumulative case Comprehensive Study Level EA Caribou Project Federal and Provincial Screening Approved: Province of Saskatchewan 2009 Canadian Nuclear Safety Commission 2010 CNSC Approval to Construct and Operate the Caribou Project (future) Provincial Approval to Construct and Operate the Caribou Project (future) Subsequent assessments demonstrate that the past, current and planned future activities at the continue to fall within the environmental effects envelope originally reviewed by the Joint Panel. These effects considered production levels from McClean Lake to be up to 24 million lbs (10.9 million kg) U 3O 8 through the JEB Mill, based on the processing of high grade ore. To transport ore slurry on existing public roads, from McArthur River Mine to the McClean Lake Mill for a three year period. Receipt and Processing of McArthur River Ore at the McClean Lake Operation Proposal submitted: November 2009 DEIS submitted: January 2011 FEIS submitted: May 2011 Licence approval by the CNSC in 2012 McClean Lake Licence amendment Provincial approval: January 2012 Federal approval (CNSC): April 2012 Screening Level EA Project Description submitted August 2011 JEB TMF Expansion Project PD accepted as Draft EIS by CNSC February 2012 (screening level EA) Request made to CNSC staff via LCH notification in June 2016 Assessment to increase storage capacity within the facility by increasing the elevation of consolidated tailings from 434 masl to 448 masl, which corresponds to the existing ground surface on the low side of the facility. No EA required by Province July 2012 changes to CEAA removed the requirement for a screening level EA move into licensing (submitted November 2012) Page 1-11 Section 1: Introduction

20 2 Business Plan This section provides AREVA s business plan for the over the next several years. Section 2.3 provides the CNSC with an overview of potential improvement plans and significant activities that may occur at the during the next Licence term. These future activities may be subject to approvals from the CNSC pursuant to a Licence amendment or through a notification of change to the s LCH. 2.1 McClean Lake Mill Production Forecast The McClean Lake Mill production forecast is dependent on ore availability as well as market conditions. The on-going feed comes from the Cigar Lake Mine with potential to increase and maximize the mill production capacity with McClean Lake, Midwest or other source ores. 2.2 Mining Production Forecast The s mining production forecast is largely focused on evaluating the SABRE mining technique, which is a selective mining method that minimizes environmental disturbances. A mining test to extract ore from cavities is currently forecasted between 2018 and Depending on the outcome of the mining test, the market conditions, discussions with the relevant partners, and a production decision to implement the SABRE mining technique, mining of some or all of the McClean Lake remaining orebodies and/or Midwest orebodies may commence in the Licence term. 2.3 Improvement Plans and Significant Activities AREVA provides the CNSC with a forecast of activities that may occur over the Licence term. These activities will be subject to regulatory oversight of the CNSC and may require approvals and updates to the LCH Relocation of Contaminated Landfill In preparation for activities occurring within the area of the JEB TMF, including activities associated with the JEB TMF Optimization Project and the future expansion of the JEB TMF, the existing temporary contaminated landfill, which is located adjacent to the JEB TMF will be decommissioned. A new permanent contaminated landfill will be developed within the Sue C/A pit Upgrades to the Sue Water Treatment Plant To prepare for water management requirements resulting from future activities occurring at the Sue site, such as placement of potentially reactive waste rock form the Cigar Lake Mine in the Sue C/A pit, upgrades Page 2-1 Section 2: Business Plan

21 to the Sue WTP may be completed during this Licence term. Upgrades will be to improve the operation of the water treatment plant year-round and to improve the management of sludge generated from the Sue WTP. The upgrades are expected to be within the approved discharge capacity of the Sue WTP JEB TMF Expansion AREVA intends to maximize tailings placement within the JEB TMF through the construction of an embankment around a portion of the perimeter of the TMF and placement of a natural liner. The JEB TMF Expansion Project will provide the ability to increase storage capacity within the facility by increasing the elevation of consolidated tailings from 434 masl to 448 masl, which corresponds to the existing ground surface on the low side of the facility. In June 2016, AREVA provided the CNSC with a notification [13] in accordance with Appendix A of the s LCH demonstrating that the proposed Project meets the CNSC requirements and meets the intent of the licensing basis for the. The expanded JEB TMF will continue to achieve the operational and post-closure objectives developed for tailings management. Earthworks for expansion of the facility are anticipated to commence with activities related to the JEB TMF Optimization Project 2018 and will occur in phases over approximately a nine year period, as required SABRE Project In 1991, mining three of the McClean pods (pod 1, 2, and 5) using a conventional mining method was assessed and subsequently approved following a Joint Federal-Provincial Panel review process. The 1991 EIS recognized that advances in mining technology would be monitored and could support changes to the mining method [14]. The SABRE Project previously, referred to as the Mining Equipment Development (MED) Program, was initially proposed in Phase I of the SABRE Project was presented to and approved by the CNSC in 2004, which involved the completion of five mined cavities, the purpose of which was to develop and test the specialized mining equipment that would allow access to ore bodies from surface and to determine whether this alternative mining technique would be economically viable. An approval was issued after it was determined that an EA under CEAA was not required. The CNSC had concluded that the activities proposed under the SABRE Project were similar to what had been assessed in 1991, the activities being proposed were either a partial implementation of the project that was assessed in 1991, or involved changes in technology that were consistent with changes in technology expected to occur over the life of the and that would be evaluated as part of the licensing responsibilities of the CNSC. In 2006, the CNSC approved Phase II (additional 15 holes) of the SABRE Project. In 2009, the CNSC issued a Licence amendment, approving the full scope of the SABRE Project, which included the following activities: Assessment of economic viability of the re-engineered mining system; Continued efforts to optimize the mining system; and Mining of the McClean Lake Underground pod # s 1E, 1W, 2 & 5; drilling 9 months of the year. Page 2-2 Section 2: Business Plan

22 The activities currently planned for the SABRE Project are within current approvals. The SABRE team intends to complete the test mining of the approved 20 holes on pod 1E during the development of the SABRE mining method. To date, eight out of the twenty approved holes have been mined. Four additional holes, to the eight already mined in pod 1E, are planned to be drilled in 2018 and mined in At this time test mining is expected to occur on pod 1E Cigar Lake Mine Potentially Reactive Waste Rock The receipt and disposal of potentially reactive waste rock (PRWR) from the Cigar Lake Mine is expected to commence during the Licence term. The PRWR will be transported from the Cigar Lake Mine and placed in the Sue C/A pit for permanent disposal. The receipt and disposal of Cigar Lake PRWR was contemplated in the 2001 Disposal of Cigar Lake Waste Rock EIS [15], which was approved in Selenium Adaptive Management Plan Following the re-start and ramp-up of the McClean Lake Mill in 2014, AREVA identified an increasing trend in selenium concentrations in the JEB WTP effluent. A selenium adaptive management plan was developed to manage selenium related risks. To reduce selenium loadings to the environment in the near term, several continuous improvement initiatives have been undertaken, including both changes to the leaching process and changes to the tailings neutralization process. The changes to the process included an examination of potential changes to redox conditions and their impact on selenium speciation, and selenium immobilization. In 2016, after a review of several technologies, AREVA launched investigations into augmenting treatment technologies, should they be needed in future. Two processes are being investigated: the use of zero valent iron as a selenium removal technology and the BioteQ Selen-IX Process, which involves a proprietary ion exchange system, Selen-IX that removes selenium from high sulphate waters. AREVA will continue the evaluation of selenium treatment technologies in parallel with efforts to improve removal of selenium from treated effluent through improvements to existing processes, and provide updates to regulators on the progress of these activities. AREVA anticipates that selenium concentrations in treated effluent will fluctuate on short timescales, influenced by influent selenium concentrations in Cigar Lake ore and the activities in the mill to optimize processing parameters Sulphur Dioxide Mitigation In 2015, during the re-start and ramp-up, the McClean Lake Mill experienced conditions resulting in elevated Sulphur Dioxide (SO 2 ) emissions from the calciner exhaust stack, and elevated ambient airborne concentrations in and around the mill, resulting in a safety concern involving the release of, and the potential exposure of employees to, SO 2 gas. Upon recognition of this challenge, AREVA implemented a series of actions to control SO 2 emissions and exposures. AREVA has submitted to the CNSC an SO 2 Management Plan to eliminate workplace exposures to elevated SO 2 gas concentrations and minimize emissions of SO 2 from the calciner stack. The plan has been reviewed and approved by the CNSC staff. As a result of Page 2-3 Section 2: Business Plan

23 adjustments to operational and control parameters, variable stack emissions have been brought under control. In-circuit improvements in process control and in ventilation, together with monitoring and alarm systems to provide detection of ambient elevated SO 2 conditions and availability of personal protective equipment, keep workers safe. In 2016, AREVA extended the scrubber stack, to improve dispersion and minimize the potential for ground level SO 2 concentrations. AREVA will continue to monitor the adjustments made and determine if further improvement are required Potential Future Mining and Milling The mining of the Caribou deposit, the McClean deposits, the Sue D deposit, an extension to the Sue E deposit and the Midwest deposit may occur over the next Licence term. The mining of these deposits may be completed using conventional open pit, underground or the SABRE mining method. The processing of these ores and the disposal of tailings generated will occur at the McClean Lake Mill. AREVA notes that the licensing decisions for some of the potential future mining, which have not already been subject to an environmental assessment, may in some cases be required to undergo an environmental assessment under CEAA. Currently approved environmental assessments considered open pit mining of the Caribou and Midwest Project, and underground mining of the McClean deposits. Mining these deposits will require further approvals from the CNSC and the SMOE prior to commencing construction and operation. The mining of other ore bodies that have not yet undergone environmental assessment (Sue D, Sue E-extension) may be subject to environmental assessment. Modification to the McClean Lake Mill may be required to safely and efficiently process ore from the McClean and Midwest Project. These modifications have been contemplated in the Midwest EIS [16] and will require further approvals from the CNSC and the SMOE prior to commencing construction and operation. 2.4 Long term plan Although subject to economic conditions, positive development decisions, regulatory approvals and the potential to discover new orebodies through Exploration, the current long term plan for the McClean Lake Operation is presented in Figure 2-1. Page 2-4 Section 2: Business Plan

24 Figure 2-1: Long Term Plan* Mine Plan Activities at JEB Site Construction of TMF Optimization Construction of TMF Expansion Milling Cigar Lake Phase 1 Potential Milling McClean Ore Pods (SABRE) Potential Milling Midwest (SABRE) Potential Milling Cigar Lake Phase 2 Activities at Sue Site Potential Mining McClean Ore Pods (SABRE) Potential Mining of other McClean Deposits (e.g. Caribou, Sue D) Placement of Cigar Phase 1 Waste Rock Potential Placement of Cigar Phase 2 Waste Rock Activities at Midwest Site Potential Midwest Mining Test Test Development phase * subject to economic conditions, positive development decisions, and regulatory approvals Page 2-5 Section 2: Business Plan

25 3 Safety and Control Areas Section 3 discusses the following safety and control areas (SCA): Management System; Human Performance Management; Operating Performance; Safety Analysis; Physical Design; Fitness for Service; Radiation Protection; Conventional Health & Safety; Environmental Protection; Emergency Management and Fire Protection; Waste Management; Security; Safeguards and Non-Proliferation; and Packaging and Transport. 3.1 Management System The Management System SCA covers the framework which established the processes and programs required to ensure an organization achieves its objectives, continuously monitors its performance against these objectives and fosters a healthy safety culture Relevance and Management Activities at the are described and facilitated through a comprehensive Integrated Quality Management System (IQMS). The IQMS manual [17], applies to regulated activities performed by employees and contractors, and to other key activities included for business reasons. The primary objectives of the IQMS are: to provide assurance to regulatory agencies and other interested stakeholders that the product, processes and services are consistent and conducted as approved; to achieve continual improvement in the product, processes and services; Page 3-1

26 to ensure that our product, processes and services consistently meets the needs and expectations of our customers; and, to ensure that the interests of AREVA are met. The IQMS is designed to meet the requirements of the ISO 14001:2004, OHSAS 18001:2007 and ISO standards. The received the Environmental Management System Standard ISO 14001:1996 certification in 2000, and in 2005, the received certification to the ISO 14001:2004 standard. The is working towards receiving certification to the ISO 14001:2015 standard and will be compliant for certain by In 2008, the was certified under Occupational Health and Safety Assessment Series 18001:1999 (OHSAS 18001:1999), and in 2009 the received certification to the latest version, OHSAS 18001:2007. The Laboratory received certification to the ISO 17025:2005 standard in This standard specifies the general requirements for the competence to carry out tests and/or calibrations, including sampling. The IQMS is comprehensive. The activities of the employees are included in the system. Each of the key process and support service activities are managed by a department head, and the department heads are responsible for maintaining and improving quality in their respective departments. This approach establishes clear lines of accountability and responsibility with respect to quality. As presented in Figure 3-1, the General Manager of the is the most senior position on-site, is accountable for management systems and has authority over all activities on site. The General Manager and the Department Heads comprise the Management Team and have the authority for implementing the requirements of the IQMS within their departments, and across departments where necessary. Page 3-2

27 Figure 3-1: Management Team Past Performance The management system is the framework that guides the processes and programs required to ensure objectives are achieved, performance is monitored and a healthy safety culture is maintained during production, maintenance, materials handling, waste management and other activities. This includes but is not limited to requirements for work planning, change control, corrective action, document control, audits, and management review. Routine inspections by CNSC staff continue to confirm that the McClean Lake Operation is in overall compliance with these requirements. Findings made by CNSC staff are reviewed and used to strengthen existing programs and controls to ensure safety, security and the environment are not compromised. The continued to strengthen its management system during the current Licence term. The uses both internal and external audits to evaluate various aspects of site operations related to the management system and licensed activities. Internal audits are conducted by the Quality and Compliance Group (and designates) with the management system being audited on a three year rotation. An external auditor and registrar conduct audits to the ISO and OHSAS standards on an annual basis. The audits are considered either surveillance audits or re-certification audits. The re-certification audits are conducted every three years and consist of a complete audit of the system. Surveillance audits are conducted for the period between the re-certification audits and consist of pulling out portions of the management system. The was re-certified to these standards two times during the Licence term. An external auditor and registrar also conduct audits to the ISO standard. These audits are conducted on a two year rotation. Page 3-3

28 The program requires that an environmental, health and safety (EHS) compliance audit be conducted to assess conformance with applicable federal and provincial EHS regulations, site permits and approvals, and legislation at least once every three years. Results of audits are reviewed and tracked internally to ensure findings, identified opportunities for improvement, and areas of concern are reviewed by site management and responded to accordingly. There were no significant issues identified in internal or external audits completed during the current Licence term. The conducts periodic management reviews of the management system to evaluate the systems continuing suitability, adequacy and effectiveness; changes to physical, human and financial resources; and actions related to possible changes to policies, objectives, targets and other elements of the management system. AREVA continues to take opportunities to improve the safety performance and will continue to establish challenging objectives to reinforce the drive towards reducing risks. To facilitate the objectives and gauge the perception of employees in relation to safety culture, safety culture assessments are conducted regularly. The hosts an annual safety day in which management, supervision and employees partake. The safety day consists of presentations and group activities. The has a methodical change control/design control program. The purpose of the program is to ensure that changes made to the facilities, personnel or operating methods are controlled. Safety is the paramount consideration, although risks are identified and controlled and guide decisions and actions. The process determines whether or not the change can be implemented safely and considers traditional safety concerns such as industrial hygiene and personal protective equipment and process safety concerns. The has a contractor management program that is designed to manage outsourced work performed at the. The program summarizes how contractor management and oversight responsibilities will be conducted and provides requirements for monitoring contractor compliance with safety, health, environment and radiation policies and procedures and relevant legislative requirements. The submitted the IQMS manual to the CNSC staff to review and assess the status of the management system SCA in comparison to CSA N286-12, Management System Requirements for Nuclear Facilities and determine the readiness for the implementation of CSA N into the LCH. Gaps identified by CNSC staff resulted in an update to the IQMS manual, which was resubmitted to the CNSC for further review. The CNSC found the update of the IQMS acceptable and meeting requirements of CSA N Future Plans While the existing management system meets current regulatory and ISO requirements, AREVA is committed to continual improvement of the management system. Future efforts regarding the management system will be guided by updates and development of the regulatory framework, standards and REGDOC s, Page 3-4

29 as well as findings from internal audits, external audits and regulatory inspections. The new and existing circuits will continue to be audited regularly and as required, existing procedures will be augmented as new activities or equipment are integrated into the Challenges As the regulatory framework continues to develop with changes in existing standards and REGDOC s, along with the development of new standards and REGDOC s, on-going assessment and identification of gaps will be required, followed by the planning and implementation of required changes or improvements. AREVA will continue to work closely with the CNSC staff to implement new and standardized requirements under the regulatory framework in a manner mutually agreed upon and in a manner that will ensure safe and reliable operation during any implementation phase Requests The has no requests at this time. In conclusion, AREVA submits that it has the management system measures in place for the safe operation of the and in support of this Licence renewal request. 3.2 Human Performance Management The Human Performance Management SCA covers activities that enable effective human performance through the development and implementation of processes that ensure that the number of licensee staff is sufficient in relevant job areas and that licensee staff have the necessary knowledge, skills, procedures and tools in place to safely carry out their duties Relevance and Management Training activities at the are conducted in accordance with programs defined within the IQMS and adhere to the Systematic Approach to Training (SAT). The Training Group, in conjunction with the trainers in the Mill Department and applicable Safety, Health, Environment, and Quality (SHEQ) personnel are responsible for determining, coordinating, and implementing the classroom and practical onsite training. The Training Group is responsible to ensure employees are provided with the required safety training to competently perform their jobs by addressing applicable federal and provincial regulations. These training programs include classroom training, where trainees are evaluated using knowledge-based theory exams and skill-based practical assessments where applicable. Technical and other professional development opportunities are provided to employees and are conducted onsite as well as offsite. Page 3-5

30 Mill Operator and Power Engineer Operator Unit Process Training Programs are used to train new hire operators, and continued training with existing operators, as they advanced through the unit processes. Mill Operator and Power Engineer Trainee Handbooks and IQMS procedures and work instructions are used to ensure that training focuses on task competency. As well, in situations involving new circuit equipment installations and significant modifications involving vendor installed equipment; the vendor-provided training resource material is also used in the training of personnel. Training includes: classroom and on-the-job components; training with a Mill Trainer; training with a vendor; self-study; and peer training with senior operators. Trainees are evaluated using knowledge-based theory exams and skill-based weighted practical assessments during their formative training and upon training completion to ensure that they are competent in the relevant tasks and duties of each unit process. A comprehensive records system is in place to document the proficiency of operators for each unit process. A heavy equipment operator training program is used for the heavy equipment involved in reclamation and site services related operations. The training program is used to train new hire operators, current operators (refresher training), and Heavy Duty Equipment Mechanics. Training is designed to ensure that competent operators are in place for each piece of equipment. Trainee evaluations include written knowledge-based exams and competency checks including on-the-job performance observations. A comprehensive records system is in place to document the proficiency of operators for each piece of equipment Past Performance Throughout the Licence term, training programs were reviewed and updated accordingly as per the requirements of the SAT. As well, new training programs were designed, developed and implemented to meet the needs of during the Licence term. Of particular focus through the production shutdown to care and maintenance mode and then through the production ramp-up back during and after the McClean Lake Mill Upgrade Project was the review of the analysis, design, development, implementation and evaluation of the Mill and Power Engineer Operators training programs. As a result, Job Task Analysis were conducted on the Mill and Power Engineering circuits. Subsequent reviews of the trainee and trainer resources were completed and the applicable training resources were updated to reflect the required changes. To prepare for the re-start of the mill, AREVA conducted several operational specific training activities to meet specific operating objectives and to ensure the safe operation of the mill. These activities included sending Mill Operations personnel to Cameco s Key Lake Operation to observe the slurry receiving circuit in Page 3-6

31 operation and using water, waste rock, low grade ore, and finally high grade ore slurry to functionally commission/start-up the mill circuits prior to becoming fully operational. The Operations Group Mill Trainers and senior Operators trained with the engineering and installation vendors on the Leaching circuit Nitrogen Purge System that was installed for the Hydrogen Mitigation Project. The Operations Group Mill Trainers and senior Operators trained with the engineering and installation vendors on the new yellowcake packaging system. In order to meet the challenges of hiring Mill Operator personnel leading up to and during the ramp-up phase, AREVA, in partnership with Northern Career Quest (NCQ), implemented a Mill Operations Training Program. The program was and is designed to provide the trainees with the knowledge and skill required to begin working as a Mill Operator in the Operations Group. The training program includes theory and practical training including on-the-job training on mill circuits, required safety training, and powered mobile equipment training. The trainees are in essence in a learning community where they learn and live as a group. This provides them with the working and social understandings of being at a mine site working a week on/week off schedule. Since 2012, there have been seven Mill Operations Training program completed to which 80 trainees attended. Of the 78 trainees that attended, 76 completed the program and 63 were provided employment opportunities at the. AREVA, in partnership with NCQ, and the Saskatchewan Indian Institute of Technologies (SIIT), conducted a Northern Pre-Employment Skills training program in The objective of this training program was to provide training on updating workplace essential skills that would benefit the trainees who were looking for entry level opportunities at northern mine sites or in northern communities that are impact communities to the. AREVA and Cameco s northern mine sites provided a short term work placement on completion of the training program. The program had 12 trainees to which all 12 completed the program. There were three trainees who completed their work placement at and upon completion of the work placements; AREVA hired six of the trainees. AREVA in partnership with NCQ, conducted Power Engineering Trainee Training Programs. The Power Engineering Trainee Training Program provides the Power Engineer Trainees with a formal training program to assist them in preparing for completion of their certification beginning at the Fireman s Certificate level up to and including Class Three. The program includes online distance education through the Southern Alberta Institute of Technology Polytechnic (SAIT Polytechnic), certification examination preparatory courses, and on-the-job training in the Power Engineering circuits in the mill. Since 2012, there are eight current Power Engineer Trainees who have participated in the program and have achieved their next levels of certification. During the Licence term, AREVA implemented a Trades Helper Program. The Trades Helper Program is designed to prepare employees for indenturing to an apprenticeship in a specific trade. The program provides the employee with up to one year s employ working and studying alongside journeypersons to gain knowledge and skill in the trade. As well, the Trades Helper is assessed using applicable trades theory assessments and on-the-job performance to determine indenturing eligibility. There have been 10 employees enter the Trades Helper Program to which eight have successfully completed the program and been indentured as an apprentice in a trade through the Saskatchewan Apprenticeship and Trades Certification Commission (SATCC). Page 3-7

32 AREVA also conducted an onsite Supervisor-in-Training Program during the Licence term. This program involved four Supervisors who were provided with knowledge and practical training in the areas of supervisory leadership at. All four Supervisors completed the program and are employed as Mill Operations Shift Supervisors. Further reviews conducted during the Licence term on support function occupations resulted in the updating of the Radiation Protection (RP) Technician Training Program and the implementation of a formal Safety Technician Training Program and a Warehouse Attendant Training Program. During the ramp-up period, the Training personnel assumed the responsibility of delivering site wide safety training programs and as result, hired two Training Technicians. The transfer of the site wide training programs from the Safety Group to the Training Group provided for significant benefits to McClean Lake Operation. Most notably was the Training Group being able to design, develop, and deliver the site wide safety training (Lockout/Tagout, Confined Space Entry, Fall Protection, WHMIS/GHS, Fire Extinguisher, etc.) so that the Safety Group was able to focus on their primary role of maintaining site. The experience and knowledge of the two Training Technicians has provided the Training Group with the capability to offer additional training programs to personnel over and above the site safety training programs. These training programs include but are not limited to Powered Mobile Equipment (Forklift, Skidsteer, Scissor Lift, Boom Lift, and Telehandler), Vacuum Truck, High Voltage Bucket Truck, Motorized Boat Handling, and Class 1 Onsite Tractor Trailer training. The Advanced Radiation Protection training course underwent a formal review in A complete needs analysis and course design was completed to determine radiation protection instructional requirements for the receipt of high grade ore. The updated program was implemented in the fall of A subsequent review of site radiation protection in 2016 resulted in the development of a formal Advanced Radiation Protection Refresher training course as well as a specific Surface Worker Radiation Protection Module to be utilized in the Advanced Radiation Protection training course for non-mill centric workers. Practical field evaluations were developed and implemented to use as field assessments of workers to ensure learned knowledge and skill were being applied in the field workplace. The Emergency Response Team (ERT) training was reviewed during the Licence term. The review identified and updated the mandatory and optional training requirements of the ERT. The ERT members are required to meet the standards of the NFPA Industrial Fire Brigade member and the Safety Group/ERT implemented a training regime to meet this requirement Future Plans The implemented SAT at ensures that training programs are regularly reviewed. Continuous improvement is a hallmark of SAT and as such, is imbedded in the implemented training programs at. A review of the Supervisor Radiation Protection training is planned to ensure that this training meets the requirements of the development of our Supervisory/Leadership personnel at. As Page 3-8

33 a result of the previous review of the Advanced Radiation Protection training, there will be further updates implemented to the site Orientation Radiation Protection training. A Surface Worker Orientation Radiation Protection training component will be implemented into the site Orientation training for employees and contractors who work in areas that are not considered to be mill centric. It is anticipated that in partnership with NCQ, AREVA will continue to run the Mill Operations Training Program. The goal is to have one program per year up to and including Through the regular evaluation of the program, it will continue to evolve and as such, may include a formal offsite training component at a recognized post-secondary education institution. The objective of providing future trainees with offsite training at a post-secondary institution is to further develop their workplace essential skills prior to coming to McClean Lake Operation. NCQ partnership training programs that are proposed include the continuation of the Trades Helper Program, the Power Engineer Trainee Training Program, and the Supervisor-in-Training Program. AREVA has proposed an Information Technology Training Program, a Career Compass/Mentoring Program, and an Environmental Trainee Training Program to be conducted in partnership with NCQ from 2017 up to and including AREVA anticipates implementing formal individual Job/Performance Coaching to ensure the continuous personal and professional development of our personnel on a one-on-one basis at McClean Lake Operation. AREVA has committed to be fully compliant with the REGDOC , Personnel Training by December 31, Challenges The Training Group has identified that the main challenge in the future is maintaining training programs as up-to-date as possible. This challenge would be particularly applicable during instances of process changes. The action plan to meet the challenge is to continue to ensure that all aspects of the SAT are engaged for training programs and regularly evaluate and subsequently update design and deliver of programs with updated trainee and trainer resources Requests The has no requests at this time. AREVA has demonstrated that through the use of SAT, that the implemented training programs at McClean Lake Operation ensure that employees are provided with the required training to competently and safely perform their jobs. In conclusion, AREVA submits that it has the human performance management measures in place for the safe operation of the and in support of this Licence renewal request. Page 3-9

34 3.3 Operating Performance The Operating Performance SCA includes an overall review of the conduct of the licensed activities and the activities that enable effective performance. The Licence requires the to have a program in place that ensures the safe operation of its facility. The IQMS defines the programs in place to ensure on-going performance is maintained and continuous improvement is achieved. This provides an overview of how licensed activities are performed and how supporting activities enable effective performance Relevance and Management The licensed activities are performed in a controlled manner as prescribed in the IQMS. The IQMS and associated programs establish safe, uniform and efficient operating practices and processes within the facility to ensure the safety of employees, the public and the environment. The IQMS uses the Plan-Do- Check-Act methodology, and encompasses the Environmental Protection Code of Practice [18] (ECOP) and the Radiation Protection Code of Practice [19] (RCOP) for problem identification and resolution. Each COP defines action levels and administrative levels and the appropriate steps required to respond is specified in the IQMS. The IQMS is applicable to individuals such as managers, supervisors, employees, contractors, and visitors. As discussed in Section 3.1.2, appropriate changes to process, system, structure or components are managed effectively and are documented within the change control/design control process. The reports operational performance, including safety performance, to the CNSC staff annually. The results of the Radiation Protection Program and the Environmental Protection Program are reported quarterly to the CNSC staff and in the Annual Report. AREVA provides notification to the CNSC staff of any event that occurs outside of normal operations. The McClean Lake Mill operated until July 2010 when it was transitioned into a temporary shut-down. The mill underwent a safe and systematic shut-down, clean-out and flushing of each milling circuit. The JEB WTP continued to operate and treat effluent (raise water, reclaim water, sewage water and JEB site water). Minor modifications in the Tailings Preparation circuit were completed to treat water treatment plant sludge and place it in the JEB TMF. The Mill Operations and Maintenance Departments conducted inspections following the shutdown of the McClean Lake Mill to ensure deficiencies were identified and remediated prior to the mill start-up. Routine safety, health, environment and radiological monitoring continued throughout the temporary shutdown. The McClean Lake Mill underwent a successful re-start and ramp-up, with new facilities commissioned, and is able to meet production targets in each processing circuit and support facility. Monitoring of workers and workplaces verifies that the AREVA is continuing to keep worker doses ALARA while processing high-grade ore at higher production levels than previously experienced. Environmental performance objectives continue to be achieved. The Environmental Management System has proven successful in the prevention of unreasonable risk to the environment. AREVA continues to take opportunities to improve the safety performance and will continue to establish challenging objectives to reduce risks. Page 3-10

35 3.3.2 Past Performance Throughout the Licence term, the achieved its annual production targets when operating with ore grades fed through the mill ranging from 0.28% to 32.2% U. The McClean Lake Mill and associated facilities continue to operate in a manner that supports safe and reliable production in compliance with applicable standards and regulations. In 2012, AREVA received approval from the Commission to increase annual production to 13 Mlbs U 3 O 8 and process McArthur River ore. It was at the 2012 proceedings before the Commission that the CNSC staff presented and the Commission approved to adopt the LCH format, which now lists authorized activities, including the annual production rate for the McClean Lake Mill. Subsequent to this Licence amendment, the submitted a notification to the CNSC and an application to SMOE to construct the Mill Upgrade Project [5], which would increase the mill s annual capacity to 24 Mlbs U 3 O 8. Evaluation of both project and process alternatives was presented in the application, together with corresponding risk analyses. In 2013, approval of the Mill Upgrade Project was included as in the s LCH list of authorized activities [7]. The construction commenced in The construction commenced in 2013 was substantially completed in 2015, with the exception of the new Tailings Neutralization Circuit, which was completed in 2016 and commissioned with product in early In February 2016, AREVA provided a notification to the CNSC to increase the annual production capacity at the McClean Lake Mill from 13 Mlbs to 24 Mlbs U 3 O 8 [11]; the CNSC accepted this notification in May 2016 [20]. The LCH was updated in June 2016 to reflect the increase in authorized annual production rate. The first stage of the JEB TMF Optimization Project [9] was conducted in , making slope improvements and placing a liner to 439 masl. The second stage will involve sloping improvements and placement of liner to 443 masl. During the Licence term, the improved its public communication regarding reportable events through the development and implementation of the Public Information Program and Public Disclosure Protocol in accordance with RG/DG 99.1 and in response to the request pursuant to subsection 12(2) of the General Nuclear Safety and Control Regulations (GNSCR) regarding the reporting process. The Public Disclosure Protocol, in consultation with interested parties, identifies types of events posted to the AREVA website. AREVA reports unplanned events as required by the Nuclear Safety Control Act (NSCA), its regulations and the Licence conditions. During the Licence term, incidents related to health and safety, radiation protection and/or environmental performance requiring reporting to the CNSC was completed in a timely fashion, were considered low risk and none were considered of a nature that would require reporting to the Commission. AREVA reports events to the CNSC Duty Officer that trigger actions under the emergency response program, including false alarms, or when an event occurs that could trigger stakeholder interest, or an event that fits under the requirements of the GNSCR, subsection 29. Incidents are investigated through the non-conformance procedure as outlined in the IQMS. Non-conformances are identified and classified so that corrective and preventative actions are Page 3-11

36 completed to minimize and/or eliminate similar non-conformances in the future. Corrective and preventative actions are implemented and the investigation is documented as required. Noteworthy accomplishments during the current Licence term include: In 2010, the McClean Lake Mill transitioned into a temporary cessation of milling and underwent a safe and systematic shut-down. Successful completion of the McClean Lake Mill Expansion and Upgrade Projects to facilitate and annual production of 24 Mlbs U 3 O 8. In 2014 and 2015, the McClean Lake Mill underwent a safe and successful re-start and ramp-up, with new facilities commissioned, and is able to meet production targets in each processing circuit. Compliance achievement to the CSA N Management System. Updated Technical Information Documents (TIDs) including: o Environmental Performance (2012 & 2016), o Hydrogeology and Groundwater Modelling of the Collins Creek Basin (2012), o Waste Rock Management (2013), and o Tailings Management (2015). Update to the s non-conformance procedure to better facilitate investigations and documentation; The successful completion of the SO 2 mitigation strategy to reduce SO 2 emissions resulting from the Calciner stack; Completion of the Radiation Protection Confirmation Plan report demonstrating worker doses are ALARA; Safe and successful completion of projects including: o JEB TMF Optimization; o JEB Ore Pad Pond construction; o Sue C/A pit ramp; and o Hydrogen Mitigation in Leaching Future Plans The will continue to ensure safety is paramount and will focus its efforts on continual improvement and adaptive management initiatives such as a reduction in sulphur dioxide emissions and improvements in selenium loadings to the environment. AREVA will continue to invest in capital improvements at the required to ensure safe production through operating performance that provides protection for people and the environment, as required. Page 3-12

37 3.3.4 Challenges AREVA does not have any challenges associated with this SCA Requests AREVA has no requests at this time. In conclusion, AREVA submits that it has the operating performance measures in place for the safe operation of the and in support of this Licence renewal request. 3.4 Safety Analysis The Safety Analysis SCA is a systematic evaluation of the potential hazards associated with the conduct of a proposed activity or facility and considers the effectiveness of preventative and mitigating measures and strategies in minimizing the risk of such hazards Relevance and Management Facilities at the are designed according to the documented design control process, which follows the OHSAS standard requirements for hazard identification and risk assessment. The AREVA systematically assesses risk using risk analysis tools to ensure sustainable and safe operation, including hazards and operability (HAZOP) assessments, change control, hazard register, bow-tie analysis, safe work plans, and 5-point safety cards. The HAZOP approach is used to assess new processes or equipment. This focuses on equipment, instrumentation, human actions and other factors that affect the process. HAZOPs are conducted prior to making any plant modifications that may affect the safety case for the facility. Change control is completed prior to implementing changes to processes, systems, structures or components and includes an assessment of the proposed changes or modifications, identification and assessment of potential risks and impacts and proposed mitigation measures. The Change Control process ensures changes consider operational needs as well as safety, health, radiation protection, environmental protection and regulatory requirements. The hazard register is a high level identification and assessment of health and safety risks and controls across the site. The hazard register is reviewed every two years and updated as required after changes to facilities, equipment, or processes. It is also reviewed after high potential incidents, regulatory changes, and workplace inspections. Bow-tie analysis is used for an in-depth analysis of critical risks that are identified in a risk assessment or hazard register. The main objective of the bow-tie is to assess the adequacy of the existing controls for both potential causes and the possible consequences of the critical risk. Page 3-13

38 Safe work plans are also used to identify and mitigate workplace and task related hazards. Safe work plans are mainly used for non-routine work which do not have a work instruction or are not commonly performed on site. 5-point safety card focuses the attention of the workers and their supervisor on safety, their workplace, and work practices. It promotes regular interactions between co-workers and requires daily interaction with the supervisor regarding safety. Additional risk analyses maintained for the facility under voluntary, provincial or federal requirements include: Fire hazard assessments are required as part of the fire protection program as described in the IQMS. The objective of the FHAs is to demonstrate that a comprehensive assessment has been made of potential fires and that their impacts on people, equipment, buildings and the environment are acceptable. The assessment includes reference to the National Building Code of Canada, the National Fire Code of Canada, and the Code Record of Design. New proposed projects with the potential impact to fire protection are reviewed. Business Risk Model (BRM) evaluations identify hazards and mitigate risks associated with the development and implementation of projects of all sorts. The BRM evaluation is conducted at an early stage in the development process at a project level to address business risks in the planning stage; Environmental risk assessment (ERA) for the is conducted in a manner consistent with CSA N Standard for Environmental Risk Assessments at Class I Nuclear Facilities and Uranium Mines and Mills. This updated ERA is presented in the Environmental Performance (EP) Technical Information Document (TID). The library of TIDs is a leading practice, developed by AREVA, that provides a basis for continual improvement and alignment with current and developing standards (refer to Section 3.9 for more detailed information); An environmental aspects registry to meet the requirements of ISO Environmental Management System Standard; A Radiation Performance Confirmation Plan (RPCP) that was developed to validate the radiological design performance of the McClean Lake Mill while processing high grade ore through extensive data collection and analysis; and Amenability studies prior to processing ores from individual ore bodies (e.g., Cigar Lake ore) to determine the optimal operating parameters for successful processing. The amenability studies enable AREVA to determine the specific parameters for tailings preparation and waste water treatment necessary to effectively treat waste streams produced during milling. These assessments provide additional analysis specific to respective SCAs and support that the McClean Lake Operation, including the McClean Lake Mill and support facilities, are operated in a manner that is protective of the people and the environment. Page 3-14

39 3.4.2 Past Performance Safety analyses for the facility are reviewed regularly and as required depending on the type of analysis. For example, safe work plans are completed almost daily, the hazard registry is reviewed every two years (at a minimum), and the ERA documented through the EP TID is prepared every five years. Safety analyses ensure changes to the facility are controlled and that risks posed are acceptable. During the Licence term, the following activities were completed and reviewed by the CNSC staff to support the safety analysis for the facility: HAZOPs o Hydrogen mitigation HAZOP to identify a comprehensive list of hazards, operability issues, and safeguards related to the evolution and accumulation of hydrogen from the leaching of Cigar Lake ore. o o o Secondary leaching HAZOP to examine and identify any potential causes, consequences, safeguards and overall risk of deviations from the design intent of the circuit. Packaging HAZOP to identify a comprehensive list of hazards, operability issues, and safeguards for the new yellowcake packaging system. SO 2 mitigation HAZOP to examine and identify a comprehensive list of hazards, operability issues and safeguards related to Calciner gas system. Fire Hazard Assessments o In 2012, A Fire Hazard Assessment (FHA) was conducted, by a third party, for existing JEB and Sue site buildings at the. The objective of the FHA was to demonstrate that a comprehensive assessment has been made of potential fires hazards and that their impacts on people, equipment, buildings and the environment are within acceptable limits. The assessment of each building included a reference to the National Building Code of Canada (NBCC) and the National Fire Code of Canada (NFCC), both current (2010) and Code Record of Design (1995). The FHA was revised to include the mill upgrade and new construction projects including; Ammonium Sulphate Crystallization (CX), Leaching Circuit, Yellowcake and Reagents Storage Facility and the new Powerhouse. The revised FHA reflected progress made on deficiencies identified during the previous assessment. An action plan was created for remaining deficiencies. The EP TID [21] was submitted in 2016, in two volumes. Volume 1 functions as a repository of environmental performance information to provide current understanding of the environment surrounding the ; predictive risk modelling is provided in Volume 2 which includes an updated ecological risk assessment; and The Radiation Performance Confirmation Plan [22] was submitted to the CNSC in September Page 3-15

40 Recommendations from the CNSC on the safety analyses are considered continual improvement and incorporated into the management system and contribute to the overall safety of people and protection of the environment Future Plans The is required to update the ERA (as presented in the EP TID Volume 2) [21] at a minimum of every five years. In the next Licence term, this would result in at least two updates to this risk analysis, scheduled for 2021 and Other safety analyses identified will be updated regularly as described and as required. Where applicable, the updates will incorporate recommendations from the CNSC staff as well as applicable standards and guiding regulatory documents Challenges AREVA does not have any challenges associated with this SCA. The CNSC staff will be engaged in regulatory notification of any changes required within the licencing basis and ensure that the safety analyses is presented within the notifications Requests AREVA has no requests at this time. In conclusion, AREVA submits that it has the safety analysis measures in place for the safe operation of the and in support of this Licence renewal request. 3.5 Physical Design The Physical Design SCA relates to activities that impact on the ability of systems, components and structures to meet and maintain their design basis given new information arising over time and taking changes in the external environment into account Relevance and Management The maintains a program for physical design described in the IQMS. The mill and other facilities at the are designed, installed, operated and modified in accordance with the physical design program. On-going optimization and continuous improvements are made to the McClean Lake Mill circuits, equipment and associated facilities. The change and design control processes are triggered when a modification or addition to facilities, processes or equipment are proposed and are not considered a replacement in kind and therefore requires design. The aspects of the physical design process are as follows: Page 3-16

41 Change control ensures that changes made to the facilities, personnel or operating methods are controlled. Physical installations were initially designed with safety, environment, radiation protection and efficiency in mind. Safety is the paramount consideration guiding decisions and actions. The follows the change control process before any physical changes are implemented. The process determines whether or not the change can be implemented safely and considers traditional safety concerns (such as industrial hygiene and personal protective equipment) and process safety concerns. Design control - ensures the design function is performed adequately and in a controlled manner and can be triggered by the change control process, when a modification or addition to facilities, processes, or equipment is proposed which requires design. Design control is a process that ensures the design function is being performed adequately. The output of the design control process is objective evidence that appropriate consideration has been given to each stage in the design process. Proposed changes, not considered to be replacement in kind, are controlled through the change control and design control processes of the IQMS. These processes assess risks, determines if mitigation of risks can be done to an acceptable level. AREVA considers the physical design process to be effective and controlled. The process ensures safety is paramount and ensures that process safety is inherent to the design of the McClean Lake Mill and associated facilities Past Performance During the current Licence term, the made many improvements to the change control and design control process procedures as part of continual improvement and to address weaknesses as identified in audits and inspections. The improvements included developing a tiered training program for users, improved document control with the enhancement of the change control database and updates to the risk review portion of the procedure to better involve subject matter experts. The Quality Control Manual as approved by the Technical Safety Authority of Saskatchewan governs the construction, repair and alteration of pressure equipment and mechanical refrigeration equipment at the. The manual was updated and approved three times during the Licence term, with the most recent approval obtained in October As a result, the Technical Safety Authority of Saskatchewan issued a Quality Control Program Certificate of Registration and Contractors Licence to the of which expires in October The certificate of registration confirms the quality control program for pressure systems is in accordance with the applicable acts, regulations and standards. In July 2010, the McClean Lake Mill transitioned into a temporary shut-down of milling. The mill underwent a safe and systematic shut-down, clean-out and flushing of each circuit. The uses the change control/design control process to optimize the operational performance. Any equipment or facilities that were modified as a result of the temporary shutdown were controlled with the Change and Design Control Procedure. Page 3-17

42 The McClean Lake Mill underwent a safe and successful re-start and ramp-up utilizing the change and design control process where appropriate, commencing in September 2014, including commissioning of the new and upgraded mill circuits and facilities. In December 2015, AREVA provided the CNSC the Report on the Commissioning & Restart of the McClean Lake Mill [10], providing an evaluation of construction, commissioning and operating performance. During the processing of high grade ore, higher workplace radiological levels and workers doses will be observed. The McClean Lake Mill has been designed to ensure dose objectives are not exceeded. The Radiation Performance Confirmation Plan [22] describes data collection and analysis activities conducted during the ramp-up of production to confirm adequate performance and inform optimization activities. The plan confirms adequate radiological protection design of the McClean Lake Mill Future Plans is looking to enhance and improve the change control and design control program to better prioritize projects and to improve the commissioning and turn over aspects of the program. The is actively working towards continual improvement in this area Challenges AREVA does not have any challenges associated with this SCA Requests AREVA has no requests at this time. In conclusion, AREVA submits that it has the physical design measures and controls in place for the safe operation of the and in support of this Licence renewal request. 3.6 Fitness for Service The Fitness for Service SCA covers activities that impact the physical condition of structures, systems and components to ensure that they remain effective over time. This area includes programs that ensure equipment is available to perform its intended design function when called upon to do so Relevance and Management has programs and procedures that ensure the facility is operated in a safe, clean and reliable manner. These programs and procedures address the following areas that comprise this SCA: asset management through predictive and preventative maintenance (PM) program ; Page 3-18

43 an in-service inspection program; and maintenance and operating parameters. AREVA has an established PM program as defined in the IQMS. The program is administered, organized and controlled through a computerized maintenance management system (CMMS). This system manages the PM program for mill equipment and documents the equipment operating history. PM and reactive maintenance tasks are managed, initiated and documented through the work notification and work order functions of the system and are based on equipment manufacturer recommendations and equipment history. The PM work is monitored for completeness and accuracy. AREVA has an in-service inspection program which includes those related to safety significant systems. The program is comprised of secondary containment inspections, structural integrity inspections and tank integrity inspections. Qualified tradespersons are assigned to perform the initial assessment and are guided by procedures as outlined in the IQMS. Inspections are documented in the CMMS. Contract specialists are brought in from time to time dependent upon the deficiencies noted. Fire protection systems are tested according to an established schedule as outlined in the fire protection program. Third-party reviews are conducted to confirm required tests and inspections with respect to fire protection are completed and these review reports are submitted to the CNSC. The PM program ensures that systems, equipment and devices are maintained in good working order and within design specifications. Calibrations are performed and documented on instruments, controls and associated indicators. Overall, the considers the PM program to be effective Past Performance Throughout the Licence term, the PM program has proved to be successful and has been improved and enhanced in the following areas: Improvements within the computerized PM management system through the development of new processes and changes to CMMS screens for ease of planning and scheduling work; Scanning of paper work orders into the CMMS eliminated the need to retain paper copies and ensures history is captured; Considerable time, effort and resources were put towards the secondary containment inspections and backlog of work required to secondary containment structures; The enhancement of the tank integrity inspection program with further development of the inspection procedure and scheduling; Critical safety equipment such as pressure relief valves have been set up in the CMMS to be serviced or replaced at the regulated intervals; and Development of an equipment refurbishment process through the PM program that allow rebuilt equipment to be returned to the warehouse for restocking in proper locations. Page 3-19

44 Key performance indicators (KPI) are in place for the PM program and key aspects are periodically monitored and reviewed. The areas monitored through these KPI s are a measure of maintenance performance and an indication of future opportunities for improvement. Some areas reviewed are: Reserved stock inventory that moved against the work orders is an indicator of whether work is planned well and repair parts are selected correctly; Predictive and preventative maintenance compliance is an indicator of the amount of unscheduled work interrupting the planned schedule; Percentage of break in work opposed to planned work is an indicator of the health of the equipment, predictive and preventative plans and the overall maintenance effectiveness; and There are other indicators used that relate to total work order count and cost, which are reviewed periodically. The development and use of these KPI s has created transparency in the health and performance of maintenance. There has been improvements in preventative maintenance activities and progress in the accuracy and performance activities like shutdown planning through the use of KPI reporting Future Plans It is AREVA s intention to improve equipment reliability by further developing the preventative maintenance program by reviewing existing PM plans to ensure they are effective and value added in each case. An examination of the present maintenance practices to look for opportunities of improvement in areas of proactive and predictive maintenance supports a reliability focus. To help ensure our trade apprentices are maximizing their training and development, it is AREVA s plan to move to a more systematic approach to training through development of specific task instruction and verification of competency through written and physical testing. This will help the apprentice build confidence, prepare them for schooling and eventually become an independent tradesperson Challenges AREVA does not have any challenges associated with this SCA Requests AREVA has no requests at this time. In conclusion, AREVA submits that it has the fitness for service measures in place for the safe operation of the and in support of this Licence renewal request. Page 3-20

45 3.7 Radiation Protection The Radiation Protection SCA covers the implementation of a radiation protection program in accordance with the Radiation Protection Regulations. This program must ensure that contamination and radiation doses received are monitored and controlled Relevance and Management AREVA has an extensive Radiation Protection Program (RPP) to meet the requirements of the Radiation Protection Regulations. The RPP is composed of several program elements. Each element is supported by a system procedure. Each procedure describes required activities that must be performed to comply with the program objectives. The elements of the radiation program include: Doses remain ALARA (as low as reasonably achievable); Dosimetry monitoring; Radiological hazard area monitoring; Radioactive Contamination Control; Bioassay sampling for uranium in urine; Ventilation monitoring; Management of radioisotopes; Shipment of radioactive materials; Radiation Protection training; Personal protective respiratory equipment management; and Emergency response In addition to the procedures, the RPP includes the Radiation Protection Code of Practice [19] (RCOP) for the milling, including supporting facility operations, as well as the mining operations when applicable. These manuals provide information on general ALARA principles, site specific radiological protection information and direction in the event of upset conditions to ensure doses are maintained ALARA. This direction ensures regulatory compliance with the Uranium Mines and Mills Regulations and Radiation Protection Regulations are upheld. The RPP is rooted in the principle of maintaining doses ALARA while taking into account social and economic factors. This principle has been integrated into each of the elements and is implemented through each procedure at the. The verification of this principle is obtained through the dosimetry monitoring procedure which ensures adequate dosimetry monitoring is conducted for each required individual. Dosimetry monitoring documents worker exposures to gamma radiation, radon progeny and long lived radioactive dust. Dosimetry results demonstrate compliance with dose limits as defined by the Page 3-21

46 CNSC, Licence conditions and operating targets that are identified within the RCOP for the McClean Lake Operation. Routine radiological area monitoring is performed throughout the. This routine monitoring includes quantitative sampling of gamma radiation; radon progeny and long lived radioactive dust, and is comprised of a matrix of sampling locations and sampling frequencies. Each location and frequency is determined based on worker occupancy and potential radiological hazards that may be present. The routine monitoring also includes contamination control monitoring to minimize the spread of radioactive materials and provides general housekeeping assessments. Routine bioassay sampling is also established to monitor workers for uranium intake. Since many radiological hazards are airborne such as radon progeny and long lived radioactive dust, routine ventilation monitoring is performed; this monitoring measures airflow within the mill and other surface facilities. Along with monitoring requirements, routine operation and inspection of the mill ventilation systems is integrated into the operation of the process circuits. Routine reporting of results includes monthly reporting of area monitoring, quarterly reporting of official dosimetry as well as quarterly notification to workers of personal exposure. Along with the routine reporting requirements, at each stage of the mill ramp-up to a high grade, high production operation, enhanced monitoring described within the Radiation Protection Confirmation Plan (RPCP) [22] was conducted and analyzed. The RPCP report submitted to the CNSC in September 2016 included analyses of area monitoring based on each processing circuit for each radiological component. Worker doses were also analyzed based on circuit exposures and for both routine and non-routine work performed. The CNSC reviewed the RPCP and accepted the conclusions that: worker exposures would continue to be well below both AREVA dose constraints and regulatory dose limits; that ALARA opportunities were identified and implemented reducing worker doses; and finally, that design objectives for workplace radiological levels were met. As described in Section 3.2, the RPP also includes training aspects. Radiation protection training material is provided in Basic Orientation, Advanced Radiation Protection, Nuclear Gauge Training and Radiation Protection Supervisor training (Supervisors in the Nuclear Age). The intent of each training aspect is to ensure workers have an acceptable level of radiation protection knowledge, workers have increased awareness of radiological hazards in the workplace and that the knowledge of lessons learned from past events can be shared. The engineering controls that support the program were included into the strategic design and construction of the McClean Lake Mill with the specific intent to control worker radiation doses during the processing of high grade ore. The design features to isolate high radiation sources include physical barriers, shielding, containment and ventilation. Additional ALARA initiatives during the current Licence term included: ventilation design changes in the Slurry Receiving circuit to improve air quality; the introduction of quick-change pumps to minimize worker time in areas with increased hazards; Page 3-22

47 reduced sump pit volumes to reduce potential source volumes; connection of real time radon progeny detectors (Prism) to the Central Control Room Distributed Control System (DCS) to increase worker awareness of changing air qualities; introduction of Bluetooth direct reading dosimeters to improve worker awareness of gamma exposure; implementation of a designated donning/doffing location for calcining and packing enclosure entries and exits for systematic and controlled PPE donning and doffing; yellowcake drum color change to improve visual inspections for contamination control; development of movable lead walls for mobile shielding applications; and use of lead capes for individual worker shielding when required. Performance of the program is routinely assessed through the review or worker doses and area monitoring results. Worker dose reviews include the daily, weekly and monthly review of direct reading dosimeter results along with worker dose analysis and discussion at Monthly Exposure Meetings where worker doses are measured against established internal dose constraints. Area monitoring is reviewed on a daily, monthly and quarterly basis to further support doses are maintained ALARA Past Performance As the mill began the production phase of operation, ore processing included the ramping up of ore grades over time. Upon each stage of ore grade processing, enhanced monitoring was collected throughout the mill as described within the RPCP. The objective of this plan was to assess each ore grade being processed as it related to nominal area exposure rates and received worker exposure. The enhanced sampling was able to identify areas of concern where additional corrective actions were needed to maintain doses ALARA. Some examples of these corrective actions included lead shielding applications of the CCD feed tanks and slurry transfer lines near the general work areas. Figure 3-2 below demonstrates the maximum and average site doses over the past 8 years at the relative to the annualized regulatory limit of 100 msv/year. Official dosimetry is provided for It should be noted that during , McClean Lake Operation was placed in care and maintenance. The figure below demonstrates that doses are well below the annualized regulatory limit, even with the processing of high grade ore and increased production levels in 2015 and During the Licence term, there were four exceedances of the weekly Action Level of 1 msv reported, two during the ramp-up phase of the McClean Lake Mill (2015) and two during non-routine operational and maintenance activities (2016). Page 3-23

48 Dose 10 (msv) Year Average Dose Maximum Dose Annualized Regulatory Limit Figure 3-2: McClean Lake Site: Total Effective Dose (Gamma, RnP, LLRD) Future Plans The RPP is a mature program that has maintained doses ALARA. The current dose results have demonstrated the effectiveness of the program with the introduction of high grade, high production operations. The will continue to focus on reducing the top worker doses through the continuation of Job Task Observations, worker awareness, radiation protection training and application of lessons learned Challenges Doses have remained similar to past doses irrespective of increased grade and production as a result of engineered radiation protection design features of the mill, a robust RPP and a positive radiation protection safety culture on site. A foreseeable challenge relating to radiation protection will be sustaining worker vigilance while achieving low doses. Plans to measure, engage and promote worker ALARA practices will include having top dose workers attend the Monthly exposure meetings, having radiation protection staff integrate into Operations and Maintenance morning roll-out meetings and weekly safety huddles and engaging workers more frequently through Job Task Observations Requests AREVA has no requests at this time. In conclusion, AREVA submits that it has the radiation protection measures in place for the safe operation of the Licence renewal request. Page 3-24

49 3.8 Conventional Health & Safety The Conventional Health and Safety SCA covers the implementation of a program to manage workplace safety hazards and to protect personnel and equipment Relevance and Management A key aspect of a safe, sustainable, and reliable operation is a comprehensive and well-established occupational health and safety program that promotes a safe and healthy workplace for employees and minimizes the occupational injuries and illnesses. AREVA has developed, implemented, and maintained health and safety policies, programs, and procedures at both corporate and operational level that meet the requirements of Canada Labour Code, Part II (Occupational Health and Safety), The Occupational Health and Safety Act, 1993 (Chapter O-1.1 of the Statutes of Saskatchewan, 1993) and The Occupational Health and Safety Regulations, 1996 (Chapter O-1.1 of the Reg 1 The Occupational Health and Safety Act, 1993). Senior management reviews the overall health and safety program regularly to determine if revisions are necessary. Regular management review meetings may identify changes required to program elements due to suitability, adequacy or effectiveness at any given time. AREVA uses an Internal Responsibility System (IRS) to ensure the safety of its workers. The IRS means everyone in the workplace has a role to play and a duty to actively ensure workers are safe by identifying, reporting, and eliminating any hazard that could injure workers. The duties and responsibilities of employers, supervisors and workers overlap and complement each other. Collectively, this is known as the internal responsibility system or IRS. The purpose of the Internal Responsibility System is as follows: Establishes responsibility sharing systems; Promotes safety culture; Promotes best practice; Helps develop self-reliance; and Ensures compliance. The requirements to have both a policy and workplace Occupational Health Committee (OHC) under Part II of the Canada Labour Code are met by the. The OHC is comprised of both employee and employer members. The OHC reviews significant changes to procedures and processes and provides suggestions. The OHC also participates in incident investigations. The OHC meets, at a minimum, every month to inspect the workplace and discuss issues that may have been brought forth to them. Minutes are posted on site bulletin boards and also forwarded to the Saskatchewan Ministry of Labour Relations and Workplace Safety. In 2008, the was certified under Occupational Health and Safety Assessment Series 18001:1999 (OHSAS 18001:1999), and in 2009 the received certification to Page 3-25

50 the latest version, OHSAS 18001:2007. The has been participating in annual maintenance audits of the Occupational Health and Safety Assessment Series OHSAS 18001:2007, verifying adherence to the management system certification. Annually, as part of the s commitment to OHSAS 18001, and to fulfil one of the responsibilities detailed within the AREVA Health and Safety Policy, internal objectives and targets are developed to promote continual improvement in the health and safety management system and thus in turn achieve an interdependent safety culture. The objectives and targets are developed based on risk assessments, internal and external audits and inspections, safety statistics, incidents, OHC inspections and minutes, 5-point safety card concerns and concerns expressed by employees Past Performance A key performance measure for the Conventional Health and Safety SCA is the number of lost time injuries (LTI s) occurring per year. LTI s are reported to the CNSC staff and are presented to the Commission as part of the CNSC staff annual regulatory oversight report. Table 3-1 summarizes the site safety performance during the current Licence term for AREVA and its contractors. Table 3-1: Total number of FTE workers, LTI, severity rate and frequency rate, Year * Total number of 1 FTE workers Number of LTIs Severity rate Frequency rate Total number of workers (employees and contractors) expressed as full-time equivalents (FTE). FTE = total person-hours / 2,000 hours worked per employee per year. 2 Lost-time injury - an injury that takes place at work and results in the worker being unable to return to work for a period of time. 3 Severity rate - the accident severity rate measures the total number of days lost to injury for every 200,000 person-hours worked at the site. Severity = [(# of days lost in last 12 months)/# of hours worked in last 12 months)] x 200, Frequency rate - the accident frequency rate measuring the number of LTIs for every 200,000 person-hours worked at the site. Frequency = [(# of injuries in last 12 months)/ # of hours worked in last 12 months)] x 200,000. *2016 values are based on data up until 2 nd quarter of 2016 As discussed in Section 2.3.7, during the re-start and ramp-up the McClean Lake Mill in 2015, AREVA identified elevated Sulphur Dioxide (SO 2 ) emissions from the calciner exhaust stack, and elevated ambient airborne concentrations in and around the mill. These conditions resulted in a safety concern involving the release of and the potential exposure of employees to SO 2 gas. Upon recognition of this challenge, AREVA implemented a series of actions to control SO 2 emissions and exposures. AREVA submitted a SO 2 Management Plan to the CNSC. As a result of the adjustments made to operational and control parameters variable stack emissions have been brought under control and with the maintenance of key processes ambient SO 2 gas concentrations are under control. Page 3-26

51 McClean Lake operation has been engaged in activities that supported continuous improvement of safety performance in the Licence period. Activities included, but were not limited to: Workplace inspections conducted by supervision, safety group, OHC, and regulatory organizations; Annual internal audits of the health and safety program elements; Annual external maintenance audit of the Occupational Health and Safety Assessment Series OHSAS 18001:2007; and Implementation of Safe Worker Award Program that encouraged employees to nominate one another to be McClean s Safe Worker of the year. In 2016, a McClean Lake employee won the Workplace and Saskatchewan Workers Compensation Board Safe Worker Award of the year for their safety initiatives Future Plans will continue to implement new corporate safety standards as well as maintain and enhance its safety program where opportunities are identified during the next Licence term. We continue to strive to continually reduce risk and achieve zero harm through our operations Challenges Legislation, best practices, and safety technology is ever changing and improving. Maintaining high safety standards and a high degree of employee awareness of safety is a challenge at any industrial operation. Until there are no injuries to any employees on the job, there will be a need to strive for improvement. AREVA is committed to maintaining a high level of safety performance and is looking for ways to continually improve aspects of the, including in the area of health and safety Requests AREVA has no requests at this time. In conclusion, AREVA submits that it has the appropriate conventional health and safety measures in place for the safe operation of the Licence renewal request. 3.9 Environmental Protection The Environmental Protection SCA covers programs that identify, control and monitor releases of radioactive and hazardous substances and effects on the environment from facilities or as the result of licensed activities. Page 3-27

52 3.9.1 Relevance and Management Environmental Protection at the is managed through the Environmental Management System (EMS) which provides a system for control of environmental issues both current and future. The EMS is designed to meet the requirements of the CNSC, the SMOE and Environment and Climate Change Canada (ECCC). Additionally, the EMS is designed to meet the criteria of the International Standard Organizations (ISO) 14001:2004 standard, and is being updated to meet the new 14001:2015 standard, as well as internal requirements. The documents that comprise the EMS identify: emissions to air, water and land; the programs that are in place to monitor them and the receiving environment; legal requirements; and reporting requirements. Two integral components of the EMS are the Environmental Monitoring Program (EMP) and the ECOP. The EMP integrates both effluent monitoring and environmental monitoring, in conformance with the Canadian Standard Association (CSA) Standards N288.4 Environmental Monitoring Programs at Class 1 nuclear facilities and uranium mines and mills, and N288.5 Effluent monitoring programs at Class 1 nuclear facilities and uranium mines and mills. In 2016, the Environmental Monitoring Program Design Document was updated to demonstrate compliance with both standards. The EMP includes monitoring necessary to demonstrate compliance with: limits set through regulation; monitoring necessary for characterization of process performance and flows; characterization of total loadings and the influences on concentration and dilution; and monitoring necessary to support continual improvement initiatives and to provide data to support the Environmental Risk Assessment framework, which assesses current and predicts future risks and evaluates them against the environmental effects predictions in the environmental assessments. The ECOP describes administrative and action levels for environmental protection, pertaining to routine operational and environmental monitoring. Examples of where administrative and action levels are applied include tailings preparation and water treatment. The McClean Lake Mill treated effluent that is released to the environment is required to comply with the Environment Canada Metal Mining Effluent Regulations (MMER) discharge limits, which are also appended to the current operating Licence. The EMS has proven to be successful in the prevention of unreasonable risk to the environment during operations to date. When action level exceedances or unplanned releases to the environment occur, steps are taken to both correct the issues and prevent them from reoccurring. These steps are handled through the site-wide non-conformance procedure outlined in the IQMS. Page 3-28

53 The EMS is an ever evolving system. As new projects are proposed and approved, additional monitoring is implemented to support predictions made in the environmental assessments. Additionally, follow-up programs to environmental assessments and updates to technical information documents and scientific modeling are ongoing. Continual improvement is at the forefront of environmental performance. Site inspections, environmental training, reviews of environmental monitoring data and systematic audits of the EMS are performed routinely. As part of the ISO EMS and to fulfil one of the responsibilities detailed within the AREVA Environment Policy, objectives and targets are created at the beginning of every year and support continual improvement and the prevention of pollution. The objectives and targets program requires participation from all departments with a significant effort put on developing a strong environment culture across site. Environmental monitoring data is compiled, interpreted and presented routinely in quarterly environmental reports and the Annual Report. Environmental Performance (EP) reports have been incorporated into the AREVA Environmental Performance Technical Information Document (EP TID) which is updated at least every five years as discussed in Section 3.4. The EP TID presents environmental performance data and compares performance to predictions presented in environmental impact assessments, reference values, federal and provincial guidelines and previous monitoring results. The EP TIDs provide a forum to ensure monitoring and follow-up programs are appropriately focused and the results are documented and communicated. The EP TID provides information related to predictive risk modelling. It was updated twice during the Licence term: in 2012 and AREVA has also undertaken the development of other TIDs, arranged by technical subject area. The TIDs provide comprehensive presentations of baseline information, operational performance data, and predictive modeling. In the licensing period updates to the Hydrogeology and Groundwater Modelling of the Collins Creek Basin, Waste Rock Management, and the Tailings Management TIDs were also completed. The Tailings Management TID has been restructured to incorporate the requirements of the Tailings Optimization and Validation Program. The TIDs serve as principle reference documents in support of the environmental assessment of new projects and activities and future licensing actions, as well as being a key component of knowledge management within AREVA Past Performance Environmental performance is reported to the CNSC routine quarterly reports and in the annual compliance reports. The McClean Lake Mill did not operate during approximately four years of the Licence term (July 2010 to September 2014), during that time point source air emissions were eliminated, only sludge from the JEB WTP was placed in the JEB TMF, and contaminant loadings in WTP effluent were very low for most contaminants Continual Improvement: During the Licence term, several flows were re-routed to optimize water use and provide more consistent feed water to the JEB WTP. Historically, the JEB TMF pond reclaim and raise water flows were directed to Page 3-29

54 the JEB WTP for treatment; freshwater was used to supply process water; and runoff from the ore pad and from the mill terrace was directed to the JEB WTP for treatment. The configuration was changed and currently raise water is used as process water, supplemented when necessary with freshwater; ore pad runoff is directed to the tailings preparation circuit; and runoff from the mill terrace is directed to the JEB TMF. Therefore, the primary feed to the WTP is now JEB TMF pond reclaim water, which is of relatively consistent quality from day to day. Other feeds include water from the process water tank, which is of consistent quality, and a small amount from the septic system. With more consistent quality of feedwater to the JEB WTP it is able to operate with fewer upsets and to produce consistently high quality effluent. Test work was performed at the Sue WTP between 2009 and 2015, with the intention of improving contaminant removal and producing better effluent quality. The configuration of the WTP was modified from a 2-stage process to a 3-stage process by adding a low ph solids-liquids intermediate clarification step. The lime addition point was moved and waste streams were rerouted as further improvements to optimize performance. These modifications were successful in improving nickel, molybdenum, and arsenic removal, and the changed configuration was made permanent at the end of The CNSC staff was notified of the permanent configuration and found it acceptable Effluent Quality Monitoring: During the Licence term contaminants in effluent from the JEB WTP were consistently below action levels and discharge limits as shown in Figure 3-3 through Figure 3-8. Results for 2016 are to June 30, U concentration (mg/l) U Action Level Figure 3-3: Uranium in JEB WTP Effluent Page 3-30

55 As concentration (mg/l) Arsenic Action Level Figure 3-4: Arsenic in JEB WTP Effluent Page 3-31

56 Mo concentration (mg/l) Figure 3-5: Molybdenum in JEB WTP Effluent Ni concentration (mg/l) Ni Action Level Figure 3-6: Nickel in JEB WTP Effluent Page 3-32

57 Se concentration (mg/l) Se Action Level Figure 3-7: Selenium in JEB WTP Effluent Ra226 concentration (Bq/L) Ra226 Action Level Figure 3-8: Radium-226 in JEB WTP Effluent Page 3-33

58 As depicted in Figure 3-7, concentrations of selenium in JEB WTP effluent have increased since re-start in Recognition of the potential for elevated concentrations downstream triggered adaptive management. A selenium investigation, management and mitigation project began in In 2010, the tailings preparation circuit was optimized to remove selenium. Continuous improvement continued after the mill restart in In 2016, AREVA submitted a Selenium Management Plan, which included four main elements: 1. Operational optimization for reduction of selenium in effluent; 2. Development of administrative and action levels for selenium as per CSA draft standard Establishing and implementing action levels to control releases to the environment from nuclear facilities; 3. Investigation into selenium removal technologies with planning for bench scale and pilot testing to determine the most appropriate for potential implementation at McClean Lake, if deemed necessary; and 4. Development of a tiered selenium risk management field studies program. The Selenium Management Plan was accepted by the CNSC in November In addition, new selenium administrative and action levels were incorporated in the ECOP. The CNSC has requested formalization of the Selenium Adaptive Management Plan. AREVA will continue the evaluation of selenium treatment technologies in parallel with efforts to improve removal of selenium from treated effluent through improvements to existing processes, and provide updates to the CNSC on the progress of these activities. AREVA anticipates that selenium concentrations in treated effluent will fluctuate on short timescales, influenced by influent selenium grades in Cigar Lake ore and the activities in the mill to optimize processing parameters, but otherwise correspond with the relatively stable annual inputs estimated within the life of mine plan. The other COPCs are displaying relatively stable concentrations which are consistent with expectations as demonstrated in. At the Sue WTP there were two exceedences of the action level for ph in August, The action level is 9.0 and two consecutive discharges were determined to be 9.15 and 9.0. Approximately 4400 m 3 of effluent with elevated ph was discharged. Effects on the environment were negligible in that the effluent did not elevate the ph in Sink Reservoir such that there would be any effect downstream. Preventative actions have been implemented to minimize the chance of off-spec effluent release in the future. The other effluent released from the Sue WTP during the licensing period has been below action levels and discharge limits Ambient Air Quality Monitoring: The ambient air quality at is monitored regularly using high volume air samples. Figure 3-9 shows the average air quality, measured in total suspended particulate, at the McClean Lake Operation between 2009 and June 30, Values are calculated as geometric means. The provincial standard is shown for comparison. Page 3-34

59 80 70 Provincial Standard 70 µg/m 3 Total Suspended Particulate Concentrations (µg/m 3 ) * *Values to June 30, 2016 Figure 3-9: Average Air Quality on McClean Lake Mill Terrace Ambient sulphur dioxide is measured continuously downwind of the acid plant. Monitoring was shut down while the acid plant did not operate between 2010 and the end of As indicated in Figure 3-10, ambient SO 2 concentrations in 2009 and 2015 were higher than in other years during the licensing period. The higher concentrations in 2009 resulted from one incident when very elevated levels of SO 2 were emitted from the sulphuric acid plant during an upset condition. In 2015, continuous operation of the calcining circuit and scrubber system resulted in greater loading to the system than had been experienced with the existing configuration of the equipment, leading to sporadically elevated emissions of SO 2 from the calciner exhaust stack. The system was reviewed and assessed, and emissions brought under control through both process improvements, and optimizing operational and control parameters. Page 3-35

60 0.012 Maximum Authorized Concentration = 0.01 ppm Average SO 2 Concentration (ppm) Figure 3-10: Average Annual SO 2 Concentrations in the Ambient Air Process improvements to control SO 2 include: The concentrations of sulphur compounds in the yellowcake product fed to the calciner are reduced by operation of the new centrifuge. The new centrifuge lessens the amount of solution entering the calciner (solids density of the yellow cake fed to the calciner is greater than before) Cleanup thickener tank level control has been improved by: increasing the overflow pump capacity; increasing the collection tank pump capacity; changing the piping for overflow tank bleed; and changing the level controls and interlocks Cleanup thickener ph control has been improved by: installing a gaseous ammonia addition line to the cleanup circuit; redirecting low ph ion exchange eluate from backwash surge tank to uranium eluate tank; and reducing use of clarified barren strip solution in the cleanup circuit. The calciner scrubber has been made more efficient at removing SO 2 from the flue gases by: increasing the scrubber demister water flow; improving pressure monitoring in the calciner exhaust ducting; improving the frequency and thoroughness of duct cleaning; addition of ph control leading to improved scrubber solution chemistry; and reducing the use of clarified barren strip solution in the cleanup circuit Additionally, the calciner stack was extended and the exit speed of the air increased to improve dispersion and reduce the concentration in the ambient air around the mill terrace. During the process of determining and implementing the planned changes the emissions were closely monitored and when determined to be elevated, corrective actions were taken immediately. Page 3-36

61 Groundwater monitoring: The has an extensive network of groundwater monitoring wells. Water levels are measured bimonthly and used to develop a groundwater flow model. Water quality is also monitored at both near field and far field locations, to confirm whether or not the operation is having any effect on the groundwater in the area. Dewatering activities during mining at both the JEB and Sue sites depressed the surrounding groundwater levels. As dewatering has lessened while the water level in the JEB TMF has risen, the surrounding groundwater level has been rebounding. Similarly, since the cessation of mining in the Sue area in 2008 the pits have been allowed to flood, and the surrounding groundwater level has also risen. Groundwater quality monitoring has not indicated any significant trends in most areas. One exception is the groundwater under the Sue clean waste rock pile which has demonstrated an increase in several ions and some metals, suggesting that a contaminant plume is forming. This plume has been modelled as part of the local groundwater flow model. This groundwater will eventually recharge Bena Lake. The model indicates that water quality in that lake will not exceed Saskatchewan Surface Water Quality Objectives at any time. The model and the conclusions are presented and discussed in the Waste Rock Management TID which has been reviewed by both SMOE and the CNSC Reportable Releases of Hazardous Substances Although the has experienced reportable spills in each year of the licensing period, the spills were cleaned-up thoroughly as described in the spill procedures outlined in the IQMS, ensuring negligible impacts to the environment. Figure 3-13 shows the number of reportable spills from 2009 through Q Page 3-37

62 9 8 7 Number of releases I * *Values to June 30, 2016 Figure 3-11: Reportable Spills of Hazardous Substances (2009 through June 2016) In 2015, the SMOE introduced new legislation around the release of hazardous substances and provided direction on the requirement to report historical discoveries as well as recordable radiological releases (RRR). An RRR is a release that exceeds the reporting requirement in the Nuclear Substances and Radiation Devices Regulation, but does not present a risk to public safety or the environment and therefore does not meet the provincial criteria for a reportable discharge. Two RRR s were reported by AREVA since the terminology was introduced in The reportable discharges, discoveries, and RRRs were reported to the CNSC and SMOE as required Future Plans AREVA commits to address ERA conclusions and recommendations and implement requirements of CSA standards N288.4 Environmental Monitoring Programs at Class I Nuclear Facilities and Uranium Mines and Mills, and N288.5, Effluent Monitoring Programs at Class I Nuclear Facilities and Uranium Mines and Mills. In 2016, the EMP Design Document was updated to ensure that the EMP aligns with these standards. Several supplementary studies are in progress and their results will inform future monitoring requirements. The changes resulting from the updated design document and the supplementary studies are being implemented into the EMP over the course of 2017 and Continual improvement projects in the short-term include: Page 3-38

63 introduction of monitoring for fine particulate (PM 10 and PM 2.5 ) on the mill terrace, which is being trialled during 2017; Update the EMS to meet the criteria of the new International Standard Organizations (ISO) 14001:2015 standard; and review and update effluent Action Levels to align with the upcoming CSA standard 288.8, Guideline for Establishing and Implementing Effluent Action Levels to Control Emissions from Nuclear Facilities Challenges Cigar Lake ore contains higher levels of selenium than any other ore that has been processed at the McClean Mill. Concentrations in effluent were observed to increase since the mill restarted in In quarter four 2016, selenium concentrations in JEB WTP effluent substantially decreased, corresponding to lower selenium received from the Cigar Lake ore. The has proactively implemented a selenium management plan as discussed in Section New provincial regulation on air quality due to industrial sources will come into effect for the McClean Lake facilities on January 1, Ensuring that the requirements of the regulation are met will require effort and planning Requests AREVA has no requests at this time. In conclusion, AREVA submits that it has the environmental protection measures in place for the safe operation of the Licence renewal request Emergency Management and Fire Protection Emergency management and fire protection covers emergency plans and emergency preparedness programs which exist for emergencies and for non-routine conditions. This also includes any results of emergency response exercise participation Relevance and Management Emergency planning is a requirement of the NSCA, its regulations and the Licence. In addition to the CNSC licensing requirements, ECCC and SMOE have requirements related to emergency planning and spill prevention. Emergency response planning is conducted to ensure emergency situations are responded to quickly and efficiently to protect the safety of personnel and the public, and to minimize the impact to the environment and facilities. These emergencies may include scenarios involving: Page 3-39

64 Fires Environmental spills Injury Hazardous materials spill Off-site Transportation Emergency Search for lost persons Radiation - Nuclear Devices and Restricted Areas Confined space rescue While several personnel provide assistance in the event of an emergency, certain designated positions play key roles in directing and/or supporting emergency response activities. The responsibilities and activities of specific individuals in the event of a site emergency are described in the applicable IQMS documentation. maintains an Emergency Response Team (ERT) which is trained to respond to emergencies. Training for the ERT members is provided through a variety of methods. Routine weekly training is conducted by AREVA personnel and consultants are brought to site to provide specialized training as required. This specialized training can include: Technical Rope/Confined Space Rescue; HAZMAT Responder, Wildland Fire Awareness; Advanced Medical Responder; and NFPA Industrial Fire Brigade training. Classes are verified to meet the applicable standard such as NFPA (National Fire Protection Association), St. John Ambulance or other requirements. AREVA has developed a Fire Protection Program (FPP), which applies to routine and non-routine work activities at, including commissioning, operation and decommissioning. This FPP outlines the components that comprise the overall approach to fire protection at the site. The objective of the FPP is to prevent uncontrolled fires from starting, detect, extinguish and control fires that do occur, provide adequate protection to protect structures, systems and components to life safety so that safe shut-down can be achieved if a fire does occur. The FPP also ensures: personnel, including emergency response personnel, are adequately trained with respect to fire safety and emergency response; that the comply with the National Fire Code and National Building Code of Canada; and that continual monitoring, auditing and reporting of conditions and programs occurs. Page 3-40

65 Past Performance Each year, the conducts a number of internal drills and training exercises to assess the ability to manage and respond to an emergency involving the ERT with coordinated efforts from other site groups and offsite mutual aids. A list of the types of mock emergency exercises and drills conducted over the Licence term for training purposes is provided below: Collision between forklift carrying 1000 lb propane bottle and loaded yellowcake transport truck; Table top exercise to simulate the response to an elevated hydrogen gas concentration within the Leaching circuit; Collision between a light duty pickup truck and loaded hydrogen peroxide transport truck; Joint exercise with Cameco Corporation s Cigar Lake Mine to respond to a slurry container coming loose and falling from the slurry haul truck traveling from the Cigar Lake Mine to the McClean Lake Operation; Locating and rescuing of an injured employee in a remote location using navigational equipment; Table top large scale crisis management exercise involving multiple simultaneous incidents including wildfires, search and rescue of missing ERT members, and explosion of propane cylinders causing damage to buildings; Collision between two light duty trucks involving multiple casualties and propane release; Collision between a light duty truck and 100-Ton haul truck involving multiple casualties; Hydrogen peroxide spill during a power outage; and An anhydrous ammonia line failure. Following up on the mock emergencies and drills, debrief sessions were held with the exercise participants. Positive comments and areas for improvement were exchanged. Action items resulting from the exercises were recorded and tracked to completion. The ERT participated in the 2009, 2014, 2015, 2016 Saskatchewan Mining Association annual Mine Rescue Competition. The competition was comprised of five different events. These included a first aid scenario, proficiency (gas testing, written exam and SCBA bench test) event, a surface problem (technical rope rescue), a surface practical skills event (search and rescue), and a firefighting event using 20 lb fire extinguishers. Daily, weekly, monthly, quarterly and annual checks and inspections are conducted as a part of the FPP. Checks performed as per the program include: annual fire hydrant flushes, monthly emergency equipment, wheeled extinguisher, post indicator valve, sprinkler tree, fire hose cabinets, semi-annual propane ground monitor, fire department connection, fire doors, kitchen fire suppression and hood cleaning. In 2012, a Fire Hazard Assessment (FHA) was conducted by a third party for existing JEB and Sue site buildings at the. The objective of the FHA was to demonstrate that a Page 3-41

66 comprehensive assessment has been made of the potential fires and that their impacts on people, equipment, buildings and the environment are within acceptable limits. The assessment of each building included a reference to the National Building Code of Canada (NBCC) and the National Fire Code of Canada (NFCC), both current (2010) and Code Record of Design (1995). The FHA was revised to include the mill upgrade and new construction projects including: Ammonium Sulphate Crystallization (CX); Leaching Circuit; Yellowcake and Reagents Storage Facility; and the new Powerhouse. The revised FHA reflected progress made on deficiencies identified during the previous assessment. An action plan was created and tracked for remaining deficiencies Future Plans The will continue to review the REGDOC , Nuclear Emergency Preparedness and Response and implement sections applicable to uranium mines and mills by December The FHA will be revised in 2017 to include the changes to the site since the last revision Challenges AREVA does not have any challenges associated with this SCA Requests AREVA has no requests at this time. In conclusion, AREVA submits that it has the appropriate emergency management and fire protection measures in place for the safe operation of the Licence renewal requests Waste Management Waste management covers internal waste-related programs that form part of the facility s operations up to the point where the waste is removed from the facility to a separate waste management facility. This area also covers the planning for decommissioning. Page 3-42

67 Relevance and Management The has a waste management plan that forms part of the IQMS. The waste management plan describes how waste is managed, and by whom, throughout its lifecycle at the McClean Lake Operation to the point of disposal - may it be on-site or off-site. The plan has an overall objective to reduce, reuse and recycle. personnel, including short and long-term contractors, are trained and regularly reminded of proper waste segregation and waste disposal. The handles both conventional waste and radiologically contaminated waste. Facilities for handling waste include: waste rock piles; the JEB TMF; several landfills; an incinerator; the hydrocarbon landfarm; the sewage solids disposal area, the special waste pad; and the hazardous materials (HAZMAT) pad. Additionally, many domestic and industrial wastes are recycled. Waste volumes are tracked and reported annually to the CNSC as part of the Annual Report Preliminary Decommissioning Plan AREVA maintains a Preliminary Decommissioning Plan (PDP) and Financial Assurance (FA) for the as per requirements of the General Nuclear Safety and Control Regulations and the provincial Mineral Industry Environmental Protection Regulations. The PDP and FA is intended to provide sufficient planning for decommissioning to ensure adequate financial assurances are in place to decommission the should a governmental agency need to assume responsibility for decommissioning the site in the unlikely event AREVA is unable to fulfill its obligations. AREVA is obligated to decommission the at the end of its lifecycle and will provide detailed plans for regulatory approval prior to commencing final decommissioning activities. The PDP is reviewed and revised every five years and will be reviewed and updated at least twice in the proposed Licence term Past Performance The has three clean waste rock piles, which include the JEB, Sue C and Sue E piles that were derived from open pit mining operations that took place from 1999 to AREVA monitors Page 3-43

68 the effects of the clean waste rock piles. In June 2013, AREVA provided results of the monitoring to the CNSC in a document entitled Waste Rock Management Technical Information Document [23]. Conclusions of the TID were: Monitoring data to date shows that undesirable waste rock has been segregated from the clean waste rock piles; and Disposal of problematic waste in the Sue C/A Pit is not epected to result in concentrations of contaminants of concern that exceed the SSWQO in receiving surface water bodies under any scenarios considered. Mill tailings are placed subaqueously in the JEB TMF via tremmie. The quantity, density, and concentration of contaminants in solids and porewater are monitored and reported quarterly. Contaminants of concern (e.g., arsenic) concentrations were below the ECOP quarterly and annual action levels throughout the licensing period. The special waste pad originally held mining wastes, however have been transferred to the Sue C/A Pit for disposal. Since 2002, the special waste pad has been used primarily to store sludges removed from settling ponds during cleaning. Hydrocarbon contaminated soil is placed in the landfarm for rehabilitation. Similarly, solids from the sewage system are placed in the disposal area. Both the landfarm and the solids disposal area are on top of the JEB waste rock pile. Most waste generated on site is categorized into: Domestic waste; Industrial waste; Contaminated waste; and Hazardous waste. Domestic waste consists of green waste (food and kitchen wastes) and non-recyclable materials. Since 2002, domestic waste contained in garbage bags collected from the JEB site, Sue site, and camp has been incinerated in an effort to reduce the use of the domestic landfill, as well as to reduce the potential for wildlife attraction to the landfills and other site infrastructure. Domestic wastes that are not incinerated are transferred to the Moffat domestic landfill where they are buried to reduce the potential spread of refuse by wind and animals. Non-recyclable plastics and glass are buried in the industrial landfills located near the JEB and/or Sue waste rock piles. Page 3-44

69 A blue box recycling program is maintained on site and paper and cardboard, domestic plastic and metal, and computer and printer components are collected and sent off site for recycling. Additionally, drink containers are collected by housekeeping staff and sent for recycling. Industrial wastes consist of industrial packaging materials (styrofoam and plastic), some scrap wood, tires, metal and other waste construction materials, and are placed in the industrial waste landfills at the JEB and Sue sites. Clean waste wood is segregrated and stored for burning. Chemically and radiologically contaminated wastes are placed in the temporary contaminated landfill located within the hydraulic containment area at the brow of the JEB TMF. Radiologically contaminated waste originates primarily from the McClean Lake Mill, as well as the JEB and Sue WTPs. Industrial materials that are sent off-site for recycling include: fluorescent light bulbs, antifreeze, waste oil and grease, waste oil/fuel filters, and batteries. These materials are stored in drums on the hazardous materials storage (HAZMAT) pad until they are shipped off site. Double walled tanks are used to store used oil at both the JEB and Sue maintenance shops. Waste dangerous goods are also stored on the HAZMAT pad until they are shipped off site for disposal at a registered facility. These goods include paint and paintrelated materials, and various chemicals. Waste facilities are monitored regularly to ensure proper segregation Future Plans The intends to relocate the material from the temporary contaminated landfill to the Sue C/A pit. A notification for the CNSC acceptance of this project was provided to the CNSC staff in In addition, the JEB special waste pad will be used as a temporary staging area for contaminated waste between when it is generated and when it is moved to the Sue C/A pit for final disposal. The Sue site office complex will be torn down and disposed of in the Sue or JEB industrial landfills, as the buildings are in poor condition and are not salvageable. A notification will be submitted to the CNSC staff for this activity Challenges It may be necessary to extend the existing industrial landfills or build a new one. Current requirements for landfills are stringent, and building a new landfill would be a challenging project. Disposal of sludge from the east temporary sludge pond poses a challenge. The sludge is water treatment plant sludges stored from the early years of operation, mixed with ammonium sulphate solution. The is currently working on a solution. Page 3-45

70 Requests An updated version of the PDP was submitted to the CNSC in October 2016 and has been determined acceptable by the CNSC staff. The confirms that the financial guarantees are in place and approved by the Province of Saskatchewan. The updated version of the financial guarantee provided in the revised PDP [1] of $107,240,000 is awaiting approval by the Commission. In conclusion, AREVA submits that it has the appropriate waste management measures in place for the safe operation of the Licence renewal requests Security The Security SCA covers the programs required to implement and support the nuclear security requirements stipulated in the General Nuclear Safety and Control Regulations (GNSCR) and other CNSC requirements Relevance and Management The implements and maintains security measures to prevent the loss of nuclear substances and prevent acts of sabotage at the facility. The IQMS outlines the responsibilities of the Security Group with respect to site security, site access and assisting with emergency response. The objective of the security plan is to ensure safe and secure operation of the facility, by maintaining protection through use of equipment, personnel and procedures Past Performance The has undergone numerous Security Threat and Risk Assessments (STRA), with the most recent conducted in The STRA report was submitted to the CNSC for review in November The CNSC found the report to be acceptable. Findings and recommendations issued by the CNSC are used to improve the overall security program Future Plans Although the has had no security threats or issues in the past, AREVA has determined that a regular review of the STRA is required and has created a procedure within the IQMS to ensure the STRA is reviewed on a regular basis. The implements sections of REG DOC , Security of Nuclear Substances: Sealed Sources applicable to applicable to uranium mines and mills by December Challenges AREVA does not have any challenges associated with the SCA. Page 3-46

71 Requests AREVA has no requests at this time. In conclusion, AREVA submits that it has the security measures in place for the safe operation of the and in support of this Licence renewal request Safeguards and Non-Proliferation The Safeguards and Non-Proliferation SCA covers the programs and activities required for the successful implementation of the obligations arising from the Canada/International Atomic Energy Agency (IAEA) safeguards agreements, as well as all other measures arising from the Treaty on the Non-Proliferation of Nuclear Weapons Relevance and Management The site maintains inventories for radioactive material (mainly uranium ore concentrate) where receipts and shipments are recorded. Periodic audits of the inventory system are conducted by the IAEA, the CNSC and by AREVA internal auditors. Uranium accountability controls and practices are in place through the accountability system to comply with the applicable nuclear materials safeguards requirements of the CNSC Past Performance The maintains a uranium inventory system in which receipts and shipments are recorded as per the requirements of RD-336 Accounting and reporting of nuclear material. CNSC Inventory Change Documents (ICD s) are submitted for each shipment of radioactive material (mainly uranium ore concentrate). Annual reports are submitted to the CNSC International Safeguards Division using the IAEA Protocol Reporting software. The grants complimentary access to the IAEA as requested. The IQMS describes the IAEA access site and how it is to be handled. Periodic audits of the inventory system are conducted by the IAEA, the CNSC and by AREVA internal auditors. The most recent audits completed by the IAEA, the CNSC and AREVA were in May 2016, November 2016 and December 2016, respectively. The McClean Lake Operation continues to work with both the CNSC and IAEA on continual improvement in this area Future Plans The will continue to comply with IAEA requests and ensure that prompt access are granted to the IAEA at all reasonable times where access is required by the IAEA for purposes of carrying on an activity pursuant to the safeguards agreement. Page 3-47

72 Challenges AREVA does not have any challenges associated with this SCA Requests AREVA has no requests at this time. In conclusion, AREVA submits that it has the safeguards and non-proliferation measures in place for the safe operation of the and in support of this Licence renewal request Packaging and Transport The Packaging and Transport SCA includes programs that cover the safe packaging and transport of nuclear substances and radiation devices to and from the licensed facility Relevance and Management AREVA has procedures and supporting documents related to the handling, storing, loading, transporting and receipt of nuclear substances and other dangerous goods. Nuclear substances to and from McClean Lake site are transported on public roadways, railways and marine transport globally and comply to the Transportation of Dangerous Goods Regulations (TDGR) and the Packaging and Transport of Nuclear Substances Regulations, 2015 (PTNSR). The responsibilities of the packaging and transportation of nuclear substances is managed by three groups: Mill Operations, Radiation Protection and Materials Management. Generally, the Mill Operations Group is responsible for the packaging and loading, the Radiation Protection Group is responsible for radiation assessments and monitoring of shipped radioactive materials and the Materials Management is responsible for the shipping documentation. Employees involved in the radioactive shipment process are trained in the safe handling, packaging, marking, labelling, shipping and receipt of dangerous and/or radioactive goods commensurate with their responsibilities. verifies that recipients of radioactive shipments from McClean Lake hold a valid license to possess such prescribed substances prior to shipment departure. Additionally, if required by the Nuclear Non-proliferation Import and Export Control Regulations, an import or export license is obtained from the CNSC prior to shipment and corresponding import or export permits are also obtained from Global Affairs Canada. A condition of the Transport of Dangerous Goods Regulations requires AREVA to have an approved Emergency Response Assistance Plan. The AREVA Emergency Response Assistance Plan (ERAP) has received approval from Transport Canada for the transport of radioactive shipments. These shipments Page 3-48

73 include, but are not limited to, shipments of uranium concentrate (U 3 O 8 ) and uranium ore slurry totes transported between and Cigar Lake Mine. Ore Slurry Truck Dimensions: Length = 27 meters; Width = 2.74 meters; Ore Slurry Truck Weight (loaded) = 81 metric tonnes; Weight (unloaded = 50.8 metric tonne Figure 3-12: Ore Slurry Truck: Tractor, Trailer and Containers Past Performance U 3 O 8 is produced, packaged in IP-1 rated steel drums and transported by road in trailer vans and/or ISO sea containers from the to the Saskatoon marshalling yard where the shipments are inspected before furtherance to the consignee. The drums remain in the same trailer or container as they were packaged in at until they reach their destination in North America or overseas. Shipments adhere to applicable acts and regulations. The receives shipments of ore slurry from the Cigar Lake Mine. The ore slurry is packaged in approved IP-2 ore slurry totes and adheres to applicable acts and regulations during transport. During the current licence period the CNSC was notified, as per reporting requirements of PTNSR, of 7 transportation events involving ore slurry totes. Reportable events related to the shipment exceeding surface contamination limits prescribed by PTNSR. Each event was investigated, corrective actions put into place with no environmental impacts occurring as a result Future Plans will continue to comply with applicable federal and international transportation regulations as appropriate Challenges AREVA does not have any challenges associated with this SCA. Page 3-49

74 Requests AREVA has no requests at this time. In conclusion, AREVA submits that it has the appropriate safe packaging and transport of nuclear substances and radiation devices to and from the as required. Page 3-50

75 4 Other Matters of Regulatory Interest 4.1 AREVA s Public Information Program and Aboriginal Engagement Activities The is located in northeastern Saskatchewan within the Northern Administrative District of Saskatchewan (NAD). The NAD is approximately half of the size of Saskatchewan but contains less than 4% of the population or about 37,000 people. Figure 1-1 in Section provides the location of the in relation to its neighboring communities, some of which are only accessible by air and winter roads. AREVA formalized its public engagement program in the Public Information Program (PIP) for the McClean Lake Operation in accordance with the Nuclear Safety Control Act, the Uranium Mines and Mills Regulations and assessment criteria outlined in RD/GD 99.3 Public Information and Disclosure. The PIP outlines how AREVA will ensure that information related to the health, safety and security of persons and the environment, and other activities associated with the facility are effectively communicated to the public. The PIP was developed with the following intended objectives: encourage early information-sharing about the to address the perceived risk to health and safety of the workers, the public and the environment from the McClean Lake Operation; communicate key AREVA business decisions as it relates to the ; and provide opportunities for stakeholders to engage in a dialogue with AREVA about issues, comments, concerns, and questions regarding on-going or proposed activities at the. Due the large size of the NAD (Figure 4-1), and the remoteness of the, AREVA s PIP activities focus broadly on the communities of the NAD, but emphasize the communities located closer to, and which have had a historical relationship with, the. The PIP identifies various communications tools and approaches to providing information related to the s activities and help address perceived environmental, health and safety risks to stakeholders. No one tool or approach can satisfy the information needs of all groups or target audiences. Rather, a coordinated strategy using several types of communication tools is required to ensure groups are adequately informed. The commonly utilized communication tools include items such as brochures, newsletters, videos, targeted website information and blogs. Wherever possible, AREVA strives to make the informational material available on the internet, through the AREVA website and social media. Face-to-face meetings and participation in community events are also an important aspect of the PIP. Page 4-1 Section 4: Other Matters of Regulatory Interest

76 Figure 4-1: Northern Saskatchewan Administrative District AREVA makes every effort to record the questions, comments, and concerns made during meetings or discussions with stakeholders or target audiences. These questions, comments and concerns are recorded and carefully tracked and assessed to determine potential changes to proposed projects, level of interest in projects, areas for improvement, improving communication and engagement tools. In addition to taking notes during meetings, AREVA staff use a standardized comment form during community visits or open house forums to record attendees questions, concerns and/or statements. Comment sheets are occasionally provided to attendees with specific questions on a variety of topics. These survey sheets are collected and the comments and questions noted are recorded and reported in AREVA s project-specific Page 4-2 Section 4: Other Matters of Regulatory Interest

77 annual reports to regulators. AREVA responds to the inquiries, concerns and questions from groups and individuals that are submitted or recorded during a meeting. Aboriginal Engagement Activities As the McClean Operation is located in northern Saskatchewan, where over 80% of the residents selfidentify as Aboriginal, AREVA is strongly committed to ensuring that opportunities are afforded to Aboriginal communities, members, and leadership to engage with AREVA about the throughout the licensing process and the subsequent icence term. This commitment is also articulated in s PIP, further described above in Section 4.1. The PIP describes AREVA s various levels of target audiences. Level I Target Audience include those primarily from the Athabasca Basin, a region home to the three First Nation communities of Black Lake Denesuline First Nation, Fond du Lac Denesuline First Nation and Hatchet Lake Denesuline First Nation, and four municipalities: the Northern Settlement of Wollaston Lake, the Northern Settlement of Camsell Portage, the Northern Settlement of Uranium City, and the Hamlet of Stony Rapids, in which a number of Métis individuals reside. As part of the Collaboration Agreements of which AREVA is party to, AREVA, Cameco Corporation and a number of Aboriginal communities have a unique engagement process about the, which are small committees, comprised of appointed community members and representatives from AREVA and Cameco. These committees and their duties are enshrined in the various Collaboration Agreements. One of the significant duties is for the committees to review environmental information about the various Operations and provide feedback to the companies regarding any questions and concerns. For the McClean Lake Operation, the Ya Thi Néné Collaboration Agreement established a key committee, referred to as the Athabasca Joint Engagement and Environmental Stewardship Subcommittee (AJES). Engagement Activities The Licence renewal is an important licensing action, and as such, AREVA has developed specific Public Engagement strategy to ensure that interested members of the Public, including Aboriginal community members and leadership, would have an opportunity to be informed and engaged about the Licence renewal. Table 4-1 provides a list of engagement activities that have occurred to date, with more activities planned prior to the Licence renewal hearing. Table 4-1: Public Engagement Activities Conducted by AREVA for the MLO Renewal Organization Type of Engagement Purpose Status All Hatchet Lake First Nation / Wollaston Lake Website Community meeting Post Information related to McClean Lake Licence Renewal on AREVA Resources Canada website Joint community meeting with the CNSC 101 session to discuss the MLO Licence Renewal Ongoing Completed, October 11, 2017 Page 4-3 Section 4: Other Matters of Regulatory Interest

78 Organization Type of Engagement Purpose Status Ya thi Néné Lands and Resources Office (YTNLRO) Pinehouse Collaboration Agreement Environment Subcommittee ERFN Collaboration Agreement Environment Subcommittee MLO Employees AJES NAD Communities Athabasca Basin Communities (Fond du Lac, Hatchet Lake, Black Lake, Stony Rapids, Uranium City, Camsell Portage) Lac La Ronge Indian Band Hatchet Lake First Nation Hatchet Lake First Nation Hatchet Lake First Nation Regular, ongoing communication and information sharing Notice at Meeting Notice at Meeting Internal Media Regular AJES Meeting Opportunity North AREVA s Northern Link Athabasca Basin Newsletter Leadership meeting Leadership meeting Community meeting High school students To share information with YTNLRO on a regular basis including: Initial meeting to have general understanding about MLO Sharing of Technical Information Documents with offer to meet to discuss Sharing of relevant Regulatory documents Meeting regularly to ensure common understanding of items of interest Ensure awareness of MLO Licence Renewal and submission for intervenor funding requests Ensure awareness of MLO Licence Renewal and Submission for intervenor funding requests Regular information to employees about MLO Licence Renewal and relevant information Provide a high level overview of the MLO Licence Renewal request. Ensure awareness of submission for intervenor funding requests Provide a high level overview of the MLO Licence Renewal request Provide a high level overview of the MLO Licence Renewal request Provide a high level overview of the MLO Licence Renewal request, with some requested information shared following the meeting AREVA, the CNSC, and the Ya thi Néné Lands and Resources Office jointly coordinated. Discussion on the Ya thi Néné Collaboration Agreement, the CNSC Regulatory Process, and the environmental, health and safety protection at the MLO Completed December, 2016 Completed February, 2016 Completed March 2016 Ongoing Completed in December, 2016 Completed in December, 2016 Ongoing Completed December, 2016 Completed December, 2016 Completed December, 2016 Completed January 19, 2017 Completed January 24, 2017 Completed January 24, 2017 Postponed due to travel times Page 4-4 Section 4: Other Matters of Regulatory Interest

79 Organization Type of Engagement Purpose Status Black Lake First Nation Black Lake First Nation Black Lake First Nation Fond du Lac First Nation Fond du Lac First Nation Fond du Lac First Nation Clearwater River Dene Nation Leadership MLO Union Pinehouse Collaboration Agreement Environmental Subcommittee ERFN Collaboration Agreement Environmental Subcommittee Pinehouse Lake Leadership ERFN Leaders AJES Saskatchewan Environmental Society Leadership meeting Community meeting High school students Leadership meeting Community meeting High school students Leadership meeting Meeting with Leadership Regular Subcommittee meeting Regular Subcommittee meeting Leadership meeting Leadership meeting Regular AJES Meeting with two day site tour at MLO Offer to meet AREVA, the CNSC, and the Ya thi Néné Lands and Resources Office jointly coordinated. Discussion on the Ya thi Néné Collaboration Agreement, the CNSC Regulatory Process, and the environmental, health and safety protection at the MLO General discussion about the MLO, in relation to employment opportunities AREVA, the CNSC, and the Ya thi Néné Lands and Resources Office jointly coordinated. Discussion on the Ya thi Néné Collaboration Agreement, the CNSC Regulatory Process, and the environmental, health and safety protection at the MLO General discussion about the MLO, in relation to employment opportunities High level discussion about the MLO. General discussion about Licence Renewal Detailed discussion about the MLO Licence Renewal process, including performance topics relevant to the Union Discuss the MLO Licence Renewal request, in particular, the 12-year licence request Discuss the MLO Licence Renewal request, in particular, the 12-year Licence request High level discussion about the MLO, including in relation to performance, employment objectives, and business procurement High level discussion about the MLO, including in relation to performance, employment objectives, and business procurement Review detailed environment, health, safety data for the McClean Lake Operation (environmental performance, key milestones over term, future/ongoing activities) Offer to meet extended to discuss any items of interest related to the MLO Completed January 25, 2017 Completed January 25, 2017 Completed January 25, 2017 Completed January 26, 2017 Completed January 26, 2017 Completed January 26, 2017 Completed January 31, 2017 Completed February 1, 2017 Completed February 1, 2017 Completed February 2, 2017 Completed February 6, 2017 Completed February 8, 2017 Completed February 7/8, 2017 Completed February 8, 2017 Page 4-5 Section 4: Other Matters of Regulatory Interest

80 Organization Type of Engagement Purpose Status Buffalo River Dene Nation Birch Narrows Dene Nation Stony Rapids Mayor Stony Rapids Métis Representative Camsell Portage Chairperson Uranium City Chairperson Uranium City Métis Representative Wollaston Lake Chairperson Athabasca Basin Communities (Fond du Lac, Hatchet Lake, Black Lake, Stony Rapids, Uranium City, Camsell Portage) NAD Communities AJES Athabasca Basin Communities (Fond du Lac, Hatchet Lake, Black Lake, Stony Rapids, Uranium City, Camsell Portage) Letter correspondence Letter correspondence Leadership meeting Leadership meeting Leadership meeting Leadership meeting Leadership meeting Leadership meeting Athabasca Basin Newsletter Opportunity North AREVA s Northern Link Regular AJES Meeting Athabasca Basin Newsletter Provide a high level overview of the MLO in relation to the Buffalo River Dene community of Dillon, SK Provide a high level overview of the MLO in relation to the Birch Narrows Dene community of Turnor Lake, SK General discussion about the environmental, health and safety protection at the MLO General discussion about the environmental, health and safety protection at the MLO General discussion about the environmental, health and safety protection at the MLO General discussion about the environmental, health and safety protection at the MLO General discussion about the environmental, health and safety protection at the MLO General discussion about the environmental, health and safety protection at the MLO Provide information on environment, health and safety performance of the MLO Provide information on environment, health and safety performance of the MLO Respond to any items of interest raised by AJES members in relation to MLO Discuss the outcomes of the MLO Licence Renewal process Anticipated end of March, 2017 Anticipated end of March, 2017 Anticipated April / May, 2017 Anticipated April / May, 2017 Anticipated April / May, 2017 Anticipated April / May, 2017 Anticipated April / May, 2017 Anticipated April / May, 2017 Planned for April, 2017 Planned for April, 2017 Planned for May, 2017 Planned for Summer, Public Interest Survey To gauge public understanding of, and support for, uranium mining and milling in Saskatchewan, AREVA (along with Cameco Corporation) conducts public opinion surveys annually through an independent third Page 4-6 Section 4: Other Matters of Regulatory Interest

81 party. The survey approach also allows for over sampling in northern Saskatchewan to provide a better sample of the population in this part of the province, which is less populated Public Support Results from the 2016 survey confirm a high level of support for the continuation of uranium mining in the province 81% of respondents support uranium mining in the province, including 39% who strongly support the industry. This is echoed in the North, where 77% support the industry (43% strongly support). Support is high across all age cohorts. The high level of public support for uranium mining in Saskatchewan is not new. Although surveys show fluctuations in support levels, the rise and fall is within a relatively limited range as demonstrated in Figure 4-2. Figure 4-2: Public Support Consistent with previous surveys, most respondents to the 2016 annual survey (shown in Figure 4.2) have no specific concerns about uranium mining operations in northern Saskatchewan. Approximately 16% overall and 20% in the North are concerned about the industry s environmental impact. Another 13% overall and 16% North have concerns about waste management/water contamination/land reclamation, as illustrated in the graph below outlining the most frequently mentioned concerns. AREVA will continue to implement the PIP to ensure that our stakeholders are adequately informed on operations and regulatory activities occurring at the. AREVA will enhance the PIP as required to maintain stakeholders information and support levels. 4.3 Cost Recovery AREVA is in good standing with the CNSC in regards to licensing fee payment for the McClean Lake Operation. Page 4-7 Section 4: Other Matters of Regulatory Interest