Technical Review Comments. Environmental Impact Statement for the Rabbit Lake Solution Processing Project. submitted by:

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1 Saskatchewan Environmental Impact Assessment Technical Review Comments Environmental Impact Statement for the submitted by: Cameco Corporation and AREVA Resources Canada Inc. Environmental Assessment Branch Saskatchewan Ministry of Environment February, 2008

2 1. INTRODUCTION This document contains the provincial Technical Review Comments on an environmental impact statement prepared by Cameco Corporation (Cameco) and AREVA Resources Canada Inc. (AREVA) relating to the proposed transportation of up to 4.6 million kilograms of uranium per year (12 million pounds of U 3 O 8 equivalent) from AREVA s McClean Lake Operation (McClean Lake) to Cameco s Rabbit Lake Operation (Rabbit Lake) for further processing. The uranium would be transported as a partially-processed uranium-rich solution (URS) in special truck-borne containers over a dedicated haul road. The URS represents a portion of the Cigar Lake mine (Cigar Lake) uranium ore production that has been approved for processing at the McClean Lake JEB mill. The URS project would require minor changes to the JEB mill at McClean Lake, the construction and operation of a dedicated haul road between McClean Lake and Rabbit Lake, minor changes to the Rabbit Lake mill, and modifications to the Rabbit Lake In-Pit Tailings Management Facility. The URS project would utilize the existing, approved facilities at the Rabbit Lake Operation for management of other effluent streams. Pursuant to sections 11 and 12 of The Environmental Assessment Act, the Technical Review Comments are being made available for public review and comment along with the environmental impact statement for the URS project. Accompanying these documents in the public review is the federal Screening Report prepared by the Canadian Nuclear Safety Commission pursuant to the Canadian Environmental Assessment Act. 2. SASKATCHEWAN ENVIRONMENTAL IMPACT ASSESSMENT AND APPROVAL PROCESS Environmental Impact Assessments (EIA) are conducted to provide the information necessary for government to determine whether, from an environmental perspective, proposed developments, or changes to existing, approved developments, should be allowed to proceed and, if so, under what conditions. Proponents are required to prepare Environmental Impact Statements (EIS) which document the proponents conclusions on potential environmental effects of the proposed developments, or changes to approved developments, and describe the measures the proponents propose to implement to mitigate any negative environmental impacts and enhance positive impacts. The conduct an EIA and the preparation and submission of an EIS to the Minister of Environment for approval is required by The Environmental Assessment Act (the Act) Project-Specific Guidelines Saskatchewan Ministry of Environment (Ministry) prepares project-specific guidelines to assist a project proponent with the conduct of the EIA and the preparation of an EIS. 1

3 The guidelines reflect issues and concerns that are raised about the project and identify the most important information that the department feels should be included in the EIS. The guidelines, in draft form, are made available for public review prior to finalization. Technical Review of the EIS An EIS, once prepared by a proponent, is submitted to government for review. A technical review is conducted by representatives of government departments and agencies to assess whether the EIS is acceptable i.e., the EIS contains all the information requested in the guidelines. When an EIS is considered technically acceptable the environmental impact assessment documents are made available for public review and comment. Public Review of the EIS Section 11 of the Act requires that an environmental impact statement, and a review of the statement, the Technical Review Comments (TRC s), be made available for public review. The TRC s are an evaluation of the proponent's conclusions regarding the predicted environmental impacts, the significance of the predicted impacts, and the effectiveness of identified mitigative measures. In preparing the TRC s, the department focuses on those factors that are considered to be of primary significance with respect to the proposed development and to the environment. The TRC s are prepared to assist the public and the government decisionmakers to review the EIS and to evaluate the environmental acceptability of the proposed development. Pursuant to section 12 of the Act, the EIS and the TRC s are made available for public inspection for a period of not less than thirty (30) days. During the 30-day public review period members of the public may make written submissions to the Minister of Environment regarding the EIA. Ministerial Decision Following the public review of the EIS, submissions from the public, together with information generated during the technical review of the EIS, are submitted to the Minister of Environment for a decision as required by the Act. The Minister, under section 15 of the Act, may give ministerial approval to the proposed URS project and may impose any terms and conditions that the Minister considers necessary or advisable or may refuse to approve the proposed development. At any time during the environmental assessment review process, before a decision on approval is made, the Minister may require public information meetings to be held or may convene a public inquiry. 2

4 A development that has received ministerial approval cannot be constructed and operated until the proponent has applied for and received all the necessary permits, licences and approvals issued pursuant to regulations under The Environmental Management and Protection Act and other legislation. Federal-Provincial Harmonization of Environmental Impact Assessment In accordance with the Canada-Saskatchewan Agreement on Environmental Assessment Cooperation, 2005, federal and provincial environmental assessment processes are coordinated. As a consequence, environmental impact assessment documents prepared by proponents meet the requirements of both The Environmental Assessment Act (Saskatchewan) and the Canadian Environmental Assessment Act. Under the harmonization agreement, the Saskatchewan Ministry of Environment, Environmental Assessment Branch, is the lead agency and contact for the coordinated review. 3. ENVIRONMENTAL IMPACT ASSESSMENT OF THE RABBIT LAKE SOLUTION PROCESSING PROJECT (URS PROJECT) Background AREVA s McClean Lake uranium mining and milling operation received Ministerial approval under the Act on 22 December, 1993 following independent, public review by the Joint Federal- Provincial Panel on Uranium Mining Developments in Northern Saskatchewan (Joint Panel). Uranium mining at McClean Lake commenced in 1995 and milling commenced in Cameco s Rabbit Lake uranium mining and milling operation commenced operations in Cameco s Cigar Lake mine received Ministerial approval under the Act on 27 March, 1998 following independent, public review by the Joint Panel. As approved, all Cigar Lake ore will be transported to the JEB mill at AREVA s McClean Lake Operation for milling and management of mill-generated wastes. The Cigar Lake mine currently is under construction. All activities, including construction, mining, milling, and waste management, at Cigar Lake, McClean Lake and Rabbit Lake have been regulated by The Environmental Management and Protection Act, particularly The Mineral Industry Environmental Protection Regulations, The Clean Air Act and other legislation. Since the time of the initial environmental assessment approvals for the Cigar Lake, McClean Lake and Rabbit Lake operations, any proposed changes to these operations that were not consistent with the terms and conditions of the respective initial approvals have been subject to environmental impact assessment reviews pursuant to the Act. In January 2005 Cameco and AREVA submitted a proposal to the Ministry to transport uraniumrich solution from the JEB mill at McClean Lake to the Rabbit Lake mill for further processing (the URS project). 3

5 Environmental Assessment and Approval Process for the Proposed URS Project Under section 16(2) of the Act, a proposed change to a previously approved development that does not conform to the terms and conditions of that previous approval requires a Ministerial decision. The technical review of the January 2005 proposal for the URS project determined that the proposed URS project was not part of the environmental impact assessment reviews conducted by the Joint Panel or part of any previous provincial environmental impact assessment reviews conducted on the Cigar Lake, McClean Lake or Rabbit Lake operations. As a consequence, the URS project represented a change that did not conform to the terms and conditions of the respective environmental assessment approvals for the Cigar Lake, McClean Lake and Rabbit Lake operations. It should be noted that the change to the Cigar Lake environmental assessment approval is administrative, identifying that, as a consequence of the URS project, not all of the Cigar Lake ore would be processed at the JEB mill at McClean Lake as previously approved. The URS project would not require any changes to the Cigar Lake mine that would require environmental impact assessment. Subsequently, Cameco and AREVA were informed that, pursuant to section 16(2)(c) of the Act, an environmental impact assessment of the proposed URS project would be required. Project-specific guidelines for the environmental impact assessment for the URS project were provided to Cameco and AREVA in March The guidelines were provided in draft form to the public for review and comment in September-October 2005 before they were finalized. The project-specific guidelines identified key elements of the environmental impact assessment of the URS project including: characterization of the uranium-rich solution, its potential radiological and nonradiological hazards and their management; safety issues associated with the transportation of the URS; potential impacts of haul road construction and its operational issues; and tailings management in the Rabbit Lake In-Pit Tailings Management Facility at Rabbit Lake. The guidelines requested Cameco and AREVA to address other issues including: mitigation and contingency planning; monitoring; decommissioning, reclamation and abandonment. The guidelines also requested that the EIS discuss: whether previous modeling predictions for the McClean Lake and Rabbit Lake sites have been verified by current operational monitoring data; and 4

6 whether historic exploration and industrial development activities have influenced the current status of the environment, fisheries, wildlife or resources use at the site of the proposed URS project. The guidelines included requirements to ensure that the information in the EIS would be sufficient to address the approval and regulatory concerns not only of Saskatchewan but also those of federal agencies. Environmental Impact Statement In November 2006 Cameco and AREVA submitted an EIS for the proposed URS project to federal and provincial environmental assessment agencies for technical review. Following the technical review these agencies provided a compilation of technical review comments on the EIS to Cameco and AREVA and requested technical responses. Cameco and AREVA submitted their responses to the agencies in May Following review of the responses, the federal and provincial environmental assessment agencies informed Cameco and AREVA that they were considered acceptable by technical reviewers. Subsequently, Cameco and AREVA incorporated the technical responses into the EIS. Public Review of Environmental Impact Statement In January 2008, the federal and provincial environmental assessment agencies notified Cameco and AREVA that the final EIS was considered technically acceptable to be made available for public review. The public review period was set for 27 February to 28 March, ENVIRONMENTAL IMPACT STATEMENT FOR THE PROPOSED URS PROJECT The EIS describes the URS project and discusses potential alternatives for processing the Cigar Lake ore. The EIS provides a description of the existing environment, identifies potential environmental effects of the URS project, and presents an assessment of predicted effects during construction, operations and decommissioning. Other issues discussed include biophysical effects, occupational health and safety, radiation protection and socio-economics. The EIS also outlines the community and stakeholder consultation programs conducted by Cameco and AREVA. The EIS for the URS project states that the purpose of the project is to create the necessary infrastructure in order to permit the processing at the Rabbit Lake mill of a portion of the URS produced at the JEB mill at McClean Lake from the milling of Cigar Lake ore. Processing this URS at Rabbit Lake would extend the life of the Rabbit Lake Operation and eliminate the need to establish a new uranium milling facility at Cigar Lake. This reduction in infrastructure provides better project economics for the Cigar Lake Project and maintains production flexibility in the northern Saskatchewan uranium mills. The EIS notes that this approach is consistent with the opinion of the Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan that recommended that, in order to minimize the number of locations affected by 5

7 uranium milling operations, existing facilities should be used to mill ores from several mines rather than establish new mill facilities at new mines. The EIS states that the URS project would allow the Rabbit Lake mill to return to a full-time operating schedule in the short to medium term that would not only create more jobs in the medium term but also retain the existing skilled workforce that has an effective workplace safety culture. The EIS also states that, by increasing the life of the Rabbit Lake operation, the URS would allow the positive economic, employment and business opportunities generated by the Rabbit Lake Operation to continue to the benefit of the province. The URS Project and Related Changes at the McClean Lake and Rabbit Lake Operations M cclean Lake: Operational activities at McClean Lake related to the URS project would consist of pumping URS from the existing JEB mill circuit into new holding tanks and periodically transferring the URS from these tanks to truck-mounted containers for transport to Rabbit Lake along a new haul road. U RS Transportation: The EIS identifies the preferred method for transportation of the URS from McClean Lake to Rabbit Lake to by trucking the URS in special containers over a new, direct haul road between the two sites that crosses Collins Creek. The total road length would be 23 km. From McClean Lake to Collins Creek the route would utilize 12 km. of existing haul road on the McClean Lake site and then require 6.5 km. of new construction that would follow existing exploration trails. A clear-span concrete bridge would be constructed to cross Collins Creek. From Collins Creek to Rabbit Lake 4.5 km. of new construction would be required. R abbit Lake: The EIS states that the URS project would require the Rabbit Lake Operation to return to a fullnew time operating schedule as well as requiring changes to the Rabbit Lake infrastructure and operating strategy. Changes to the Rabbit Lake mill would include the construction of a receiving facility to unload the URS trucks, changes to the leach circuit, construction of a storage tank and sand filter clarification circuit and an increase in the dryer circuit capacity to a 6.5 million kg./year uranium production rate. The EIS identifies that the milling of the URS in the Rabbit Lake mill would occur in two phases: an initial co-milling phase when the URS is co-milled with ore from the existing Eagle Point mine at Rabbit Lake and a second phase when only URS would be milled. The two milling phases would result in two types of mill tailings being generated that would be deposited in the Rabbit Lake in-pit tailings management facility. 6

8 The URS project would require the tailings storage capacity of the tailings facility to be increased. The EIS states that the increase in capacity would be achieved by two means; firstly by increasing the final tailings elevation and laterally expanding the tailings facility, and secondly by actively thawing frozen layers of tailings to increase the rate of tailings consolidation. The EIS also outlines the implications of the URS project for air and water emissions at Rabbit Lake, waste rock management at Rabbit Lake, decommissioning at McClean Lake and Rabbit Lake, including the haul road, environmental monitoring and regional and cumulative effects. The EIS states that the URS project would have little impact on the McClean Lake Operation and would not require any changes to the current McClean Lake environmental monitoring or follow-up programs. The URS project would require a minor update to the current McClean Lake decommissioning plan to incorporate the new URS load-out facility in the JEB mill. The EIS states that the URS project would have little effect on the overall decommissioning plan for Rabbit Lake other than the delay of decommissioning of some facilities as a consequence of the URS project extending the life of the Rabbit Lake Operation. The EIS describes significant improvements to the decommissioning plans for the Rabbit Lake basin that are intended to minimize the overall impacts of existing and future tailings and waste rock in the Link Lake watershed. The improvements include relocating more material to the expanded Rabbit Lake tailings facility and covering above-ground waste piles. 4. TECHNICAL COMMENTS ON THE ENVIRONMENTAL IMPACT STATEMENT Technical Review The technical review of the EIS for the proposed URS project by provincial officials did not identify any significant environmental or technical issues that would require the public review of the EIS for the URS project to be delayed until the issues were resolved. The technical review did identify a number of issues related to potential environmental impacts and environmental management that required clarification. Cameco and AREVA were requested to comment on these issues that included: metals concentrations in the URS, grade and volume of low-grade uranium ore stockpiles at Rabbit Lake and implications for decommissioning, geochemical characteristics of the Rabbit Lake tailings, radon monitoring at Rabbit Lake, lake water quality monitoring, groundwater flows into the Rabbit Lake tailings facility, effluent discharge to Horseshoe Creek, haul road construction, standards, safety and maintenance, spill management, groundwater monitoring associated with the Rabbit Lake tailings facility, commitments related to maximizing benefits to local residents and businesses, trapper compensation, and access to the haul road. Other comments on the EIS related to relatively minor points. Clarification of these points was requested to improve the quality and accuracy of the EIS and add to its acceptability for public review. 7

9 Comments from some agencies advised Cameco and AREVA of regulatory requirements under various acts and regulations that would have to be met if the URS project receives environmental assessment approval. The responses to these issues provided by Cameco and AREVA were considered to be acceptable by provincial technical reviewers. As a consequence the EIS was considered technically acceptable to proceed to public review. Should the proposed URS project receive Ministerial Approval, the potential environmental impacts identified in the EIS, and any minor concerns noted during the technical review, would be addressed in detail by provincial licensing and regulatory procedures. Federal and provincial review processes were coordinated throughout the environmental assessment. Should this development proceed, the regulatory approval processes administered by the federal and provincial governments would be coordinated where possible. Environmental Issues McClean Lake The EIS did not identify any significant technical issues that would occur at McClean Lake as a consequence of the implementation of URS project. With the exception of the mill modifications required to develop the load-out facility and the implications of the removal of the URS volume from the JEB mill circuit, all activities at McClean Lake previously have been subject to environmental impact assessment. The analysis of the predicted impacts of the changes to McClean Lake as a consequence of the URS project concluded that the impacts would fall within the scope of impacts predicted by previous environmental impact assessments of the McClean Lake Operation. Haul Road The potential environmental impacts associated with the haul road construction between McClean Lake and Rabbit Lake would be mitigated by the proposed use of existing haul roads and exploration trails. New road construction would be limited to 4.5 km. The use of a pre-cast, concrete, clear-span bridge where the haul road crosses Collins Creek would avoid potential impact on fish or navigation. Biological surveys conducted along the haul road alignment did not identify any sensitive plant species or rare and endangered wildlife species and the potential impacts to wildlife were considered negligible. The potential for collisions between trucks and wildlife was considered minimal as a consequence of the limited number of daily haul trips between McClean Lake and Rabbit Lake (three to six) and the restricted truck speeds. The URS would be transported from McClean Lake to Rabbit Lake in containers similar to those used to transport uranium ore slurry from the McArthur River mine to the Key Lake mill. The containers would be subjected to drop tests to ensure their integrity in case of accidents. 8

10 Potential safety issues related to the transportation of the URS by haul trucks, e.g., accidents, spills, would be incorporated into existing emergency and spill response plans for the McClean Lake and Rabbit Lake Operations. Public access to the haul road through the surface lease areas of the McClean Lake and Rabbit Lake Operations would be restricted except for a trapper whose trapline would be crossed by the haul road. The portion of the haul road between the surface lease areas is not on surface lease lands and access to the haul road would not be controlled Cameco or AREVA. Access to the off-lease portion of the haul road through the surface leases by other mineral and surface rights holders would be considered on a case-by-case basis by Cameco and AREVA. Rabbit Lake The URS project would require the Rabbit Lake mill to return to a full-time operating schedule. The EIS identified that the potential environmental impacts of the modifications to the Rabbit Lake mill and the full-time schedule required by the URS project would be managed by the current environmental management systems already in place for the environmental and safety performance of the mill. All of the changes to the Rabbit Lake Operation required by the implementation of the URS project would be confined to the existing Rabbit Lake surface lease area that previously has been disturbed by uranium mining and milling activities. The URS project would result in additional exhaust ventilation from the URS receiving facilities at the mill, increased dryer emissions, and inert dust and fuel combustion effects resulting from increased truck traffic. The EIS stated that these effects are not anticipated to exceed current air quality standards at Rabbit Lake. The EIS described the current liquid effluent management procedures, including monitoring, treatment, and release to the receiving environment, at the Rabbit Lake site and discusses potential alterations to these procedures as a consequence of the URS project. During operations treated water from the Rabbit Lake water treatment plant is released to the Horseshoe Creek watershed that drains to Wollaston Lake. The treated water includes water from the Eagle Point underground mine, either used in the mill or treated directly, water from the Rabbit Lake tailings facility, and seepage water from the B-Zone and D-Zone open pits and the B-Zone waste rock pile. The Link Lake watershed, that drains intermittently to Wollaston Lake, would receive groundwater flows from the Rabbit Lake basin during the post-decommissioning phase of the Rabbit Lake Operation. These groundwater flows would include waters from the Rabbit Lake tailings facility and waters affected by contaminated sediments in Upper Link Lake that originated from the initial mining of the Rabbit Lake ore deposit. The EIS identified that, while the URS project would result in higher levels of arsenic and nickel in the contaminated water going to the water treatment plant from the mill, no significant changes would be required to the water treatment system to maintain current effluent quality standards. The EIS also identified that, as a result of other ongoing investigations to improve the quality of treated effluent, improvements to the water treatment system are planned. These improvements include modification to neutralization and clarification to enhance molybdenum 9

11 and selenium removal and a membrane technology plant. The EIS concluded that the URS project would not result in significant adverse environmental effects on the Horseshoe Creek watershed, the Link Lake watershed, or Wollaston Lake. The EIS stated that, based on proposed tailings volumes and consolidation analyses, an expansion of the tailings storage capacity of the Rabbit Lake in-pit tailings management facility would be required to accommodate the URS project. Currently the technical performance of tailings facility is meeting or exceeding the originally predicted performance levels despite some frozen layers within the tailings mass. Based on current tailings consolidation behaviour the EIS estimated that the hydraulic conductivity of the consolidated tailings would be below design values within a few years after final tailings deposition. The performance levels for the tailings facility were set to ensure, during operations, the physical containment of tailings solids and the full containment of tailings supernatant and pore-water and, in the post-decommissioning phase, the minimization of contaminant loading to the downstream environment. These performance levels also were set ensure that no significant adverse impact to the environment would result from the operation of the tailings facility. As noted, the URS project would require an expansion of the tailings facility. The increase in capacity would be achieved by increasing the final tailings elevation, laterally expanding the tailings facility, and actively thawing frozen layers of tailings to increase the rate of tailings consolidation. The EIS stated that, for the URS project, tailings management and waste rock management would be incorporated into an integrated management strategy. Using this strategy waste rock that is currently in surface stockpiles would be used in the construction of the lateral expansion of the existing Rabbit Lake tailings facility. This would represent an improvement to the current Rabbit Lake decommissioning plan and reduce the long-term environmental impact from existing waste rock and mineralized waste by relocating more of this material to the tailings facility. The EIS concluded that, while the changes to the tailings facility required by the URS project would result in elevated levels of some metal contaminants entering groundwater flows from the tailings facility, these levels would not result in a significant adverse impact on the environment. Cumulative Effects Currently two programs monitor potential cumulative effects from uranium mining and milling operations in northern Saskatchewan. These are the Cumulative Effects Monitoring Program established by Saskatchewan Environment and the Canadian Nuclear Safety Commission and the environmental monitoring program administered by the Athabasca Working Group that was established by an agreement between the uranium mining companies and northern communities. The EIS assessed the potential cumulative effects of the McClean Lake Operation and the Rabbit Lake Operation in combination with other activities in the area. No significant adverse effects on animals or people from the combined emissions of the McClean Lake or Rabbit Lake operations were predicted. The EIS stated that the evaluations of the monitoring data do not suggest any cumulative effects in the vicinity of Athabasca communities that can be directly linked to emissions from operational uranium mining and milling facilities. 10

12 Natural Resource Use The EIS reported the results of ecological risk assessments and the potential impacts of the URS project on natural resource use. The analyses showed that the project would have no significant effects on aquatic or terrestrial species in the area and that no effects on the availability of these resources for traditional or domestic use by Aboriginal people were expected. One trap line covers the area between Points North Landing and Collins Creek. The Impact Management Agreement sets out a claims process to address effects on local resource harvesting should they occur. To date, no claims have been filed. Environmental Regulation at McClean Lake and Rabbit Lake Operations Saskatchewan Ministry of Environment, under the Mineral Industry Environmental Protection Regulations, 1996, and other legislation, regulates all aspects of the operations at mine sites. Currently, operating approvals are in place regulating the McClean Lake and Rabbit Lake Operations. These regulatory approvals address liquid effluent management procedures and establish liquid effluent discharge limits for treated water at mine sites. Limits are included in the Operating Approvals issued by the department to ensure that the quality and quantity of treated water released will not affect the aquatic habitats and fisheries in receiving watersheds. The points of discharge and timing of releases to the receiving environment are carefully regulated. Should the URS project be approved, specific details of any changes to the current operating approvals at McClean Lake and Rabbit Lake that would be required by the URS project would be determined in consultation with the Industrial, Uranium and Hardrock Mining Unit, Saskatchewan Ministry of Environment, during regulatory licensing. Occupational Health and Safety The McClean Lake and Rabbit Lake Operations have been previously approved and all activities at these operations have to meet current provincial standards for conventional and radiological occupational health and safety. These standards are cited in the Occupational Health and Safety Act, 1993, the Occupational Health and Safety Regulations, 1996, the Radiation Health and Safety Act, 1985, the Radiation Health and Safety Regulations, 1993, and in the Saskatchewan Mines Regulations, All aspects of the proposed URS project would have to meet these same standards. The proposed changes to these operations required by the URS project would have only minor impact on the health and safety of workers and would be managed by the continued application of the occupational health and safety programs already in place at the McClean Lake and Rabbit Lake Operations. 11

13 Public Involvement and Socio-Economic Issues The Ministry is satisfied that regional residents and organizations were notified about the proposed URS project and were provided with the opportunity to be involved with the environmental assessment process. Cameco and AREVA conducted consultation activities under ongoing public information programs to keep the public informed about current uranium mining activities and new projects, to identify public issues or concerns, and to inform the public about environmental assessment and regulatory decisions affecting their projects. As described in the EIS the public consultation programs conducted by Cameco and AREVA was composed of four components: Industry Consultation with Northern Communities These programs focused on resident communities in northern Saskatchewan. These communities included Black Lake Denesuline First Nation, Fond du Lac Denesuline First Nation, Hatchet Lake Denesuline First Nation, Northern Settlement of Camsell Portage, Northern Hamlet of Stony Rapids, Northern Settlement of Uranium City, Northern Settlement of Wollaston Lake, Ile a la Crosse, La Loche, Patuanuk, Beauval, Pinehouse, La Ronge and Buffalo Narrows. Meetings were held in these communities and included community meeting presentations, school presentations, distribution of brochures and table-top displays. Materials in print format included, articles in the Opportunity North magazine, news releases, corporate newsletters, posters and handbills, advertisements in newspapers and corporate sustainability reports. Radio coverage also was used to advertise meetings and to provide a forum for interviews on special topics and for answering community questions. Technical Project Review Workshops Technical workshops were held in Stony Rapids and at the Rabbit Lake Operation on the March 6 th and 7 th, These workshops discussed the major components of the URS project. Twenty-four individuals from the Athabasca region participated. Participants included youth, elders, community leaders, Athabasca Working Group members and Athabasca Environmental Quality Committee members. Consultation on Specific Technical Issues This involved discussion of specific technical issues with groups set up to facilitate liaison between the communities and industry, particularly the Athabasca Working Group in the Athabasca region and the Athabasca Environmental Quality Committee of the Northern Mines Monitoring Secretariat. 12

14 The Athabasca Working Group Coordinator is employed by the uranium mining industry and is available to answer or re-direct concerns from community members regarding uranium developments. The Environmental Quality Committee was set up to provide a formal opportunity for industry and government to discuss technical aspects of the uranium mining industry with northern communities and their representatives. The Environmental Quality Committee reviewed the Valued Ecosystem Components relevant to the environmental impact assessment studies for the URS project on February 9, Consultation with Other Stakeholders Cameco and AREVA also communicated with other stakeholders in northern and southern Saskatchewan including non-government organizations and interest groups, regional organizations and staff of relevant government departments. Information was provided through meetings, newsletters, brochures, web-based information and presentations. Public meetings were held in Saskatoon and Prince Albert. Formal opportunities for public participation also were provided by the public reviews of the draft project-specific guidelines and the environmental impact statement that form part of the Saskatchewan environmental impact assessment process and the public review components of the federal environmental assessment review process. Several agencies commented that the listing of the public involvement programs was substantial and provided opportunity for local northern residents to be involved. The McClean Operation and the Rabbit Lake Operation currently have comprehensive protection programs for occupational health and safety and radiation protection. Given the results of current on-site and off-site programs monitoring potential environmental contaminants and the remote locations of the McClean Lake and Rabbit Lake sites, the technical review of the EIS did not foresee that the URS project would have any negative impact on worker health and safety or public health. The URS project would increase the life of the Rabbit Lake Operation and allow the positive economic, employment and business opportunities generated by the Rabbit Lake Operation to continue to the benefit of the province. The project would allow the Rabbit Lake mill to return to a full-time operating schedule in the short to medium term that would not only create more jobs in the medium term but also retain the existing skilled workforce that has an effective workplace safety culture. At peak activity, construction at McClean Lake related to the URS project would generate about 30 jobs, mainly for skilled and semi-skilled workers. The $4 million construction contract would be open to bid by northern contractors or joint ventures. Operation of the load-out facility would need an additional 4 jobs, ideally from the Athabasca region. Construction at Rabbit Lake related to the URS project would take place over two years and result in about 50 jobs for skilled and semi-skilled workers. The EIS stated that construction contracts are estimated to be about $40 million and that they were likely to be selected through 13

15 an open-bid process, with preference for Athabasca region contractors or joint ventures. Road construction would require seven months over a two-year period with a peak employment of 75 jobs, mainly skilled and semi-skilled workers. The construction contract worth $16 million would be let preferably to a northern contractor. The changes to the Rabbit Lake Operation would generate an additional 65 jobs, mainly in mill operations with other positions in administration, mining and services. Transportation of the URS would be by contractual or employment arrangements. The EIS noted that this work is part of a long-term estimated $100 million upgrade to Rabbit Lake to create a sustainable regional milling center for future Athabasca region ore deposits. Cameco and AREVA have signed Human Resource Development Agreements with the Government of Saskatchewan respectively for the Rabbit Lake and McClean Lake Operations. Both Cameco and AREVA have signed the 1999 Impact Management Agreement with six of the seven communities in the Athabasca region. These agreements set out the framework and details of the commitments and specific measures aimed at maximizing employment and business participation of residents of northern Saskatchewan in uranium mining. Multiple programs are identified that assist in the recruiting, training and retention of a northern workforce. Reviewers have noted that Cameco and AREVA, to date, have done a good job in terms of maximizing benefits for northern residents and businesses. Environmental Monitoring The EIS provides details regarding the respective modifications to the current environmental monitoring programs at the McClean Lake and Rabbit Lake Operations that would be required as a consequence of the proposed URS project. The EIS concluded that the URS project would have little impact on the current environmental monitoring plans for the McClean Lake and Rabbit lake Operations. The proposed programs incorporate the major parameters that would be required in the comprehensive monitoring plans that would be part of the Operating Approvals if the proposed URS project is approved. Should the URS project be approved, specific details of the required monitoring programs would be determined in consultation with the Industrial, Uranium and Hardrock Mining Unit, Saskatchewan Ministry of Environment during regulatory licensing. Decommissioning, Reclamation and Abandonment Current regulatory approvals issued to the McClean Lake and Rabbit Lake Operations, pursuant to the Mineral Industry Environmental Protection Regulations, 1996, include monitoring and conceptual decommissioning, reclamation and abandonment plans that are updated on a regular basis or when site operations are modified substantially. These approvals also address the current Financial Assurances that are in place for the McClean Lake and Rabbit Lake Operations to ensure that decommissioning and reclamation at these sites will not be an economic cost to the province. 14

16 The EIS concluded that the URS project, including the haul road, would have little impact on the current overall decommissioning plans for the McClean Lake and Rabbit Lake Operations. Should the URS project be approved, details of the URS project would be incorporated into the current decommissioning, reclamation, and abandonment plans in consultation with the regulatory agencies. These plans would be a component of the applications submitted by Cameco and AREVA during regulatory licensing for operating approvals and would provide the basis for calculations of financial assurances to ensure that works associated with the URS project could be decommissioned and reclaimed without cost to the province. Should the proposed URS project be approved, Cameco and AREVA would be required to submit final decommissioning plans to Saskatchewan Ministry of Environment for approval prior to the commencement of any decommissioning or reclamation activities. These plans are required by the provincial Mineral Industry Environmental Protection Regulations (1996) and the detailed requirements of the plans for decommissioning, reclamation and post-operational environmental monitoring are determined in consultation with the regulatory agencies. The Industrial, Uranium and Hardrock Mining Unit, Saskatchewan Ministry of Environment, would issue final approvals for the URS project and all related activities including decommissioning and reclamation work and post-decommissioning monitoring. Cameco and AREVA would not be released from their responsibilities for the Rabbit Lake and McClean Lake sites until the potential long-term environmental effects have been evaluated and are considered acceptable. 15