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PROJECT-SPECIFIC GUIDELINES SCOPING DOCUMENT

FOR THE

PREPARATION OF AN ENVIRONMENTAL IMPACT STATEMENT

RECEIPT AND PROCESSING OF McARTHUR RIVER ORE AT THE McCLEAN

LAKE OPERATION

AREVA RESOURCES CANADA

These guidelines have been prepared to meet the requirements for Project-Specific Guidelines for

the Saskatchewan environmental impact assessment process under the Environmental

Assessment Act and for the federal environmental impact assessment process under the Canadian

Environmental Assessment Act. The document has been prepared by the Saskatchewan Ministry

of the Environment (MOE) and the Canadian Nuclear Safety Commission (CNSC) to assist

AREVA Resources Canada Incorporated with the environmental impact assessment of the

proposed Receipt and Processing of McArthur River Ore at the McClean Lake Operation Project.

Anyone wishing to obtain additional information or provide comments on any aspect of the

environmental assessment being conducted on the project may do so through the following MOE

or CNSC staff contacts:

Lynn Kelley, Environmental Assessment Branch, Saskatchewan Environment

3211 Albert Street, REGINA, SK. S4S 5W6

Phone: (306) 787-7147; Fax: (306) 787-0930; E-mail: [email protected]

or

Nicole Frigault, Canadian Nuclear Safety Commission

280 Slater Street, P.O. Box 1046, Station B

OTTAWA, ONT. K1P 5S9

Phone: (613) 995-7948; Fax: (613) 943-9652; E-mail: [email protected]

October 2010

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TABLE OF CONTENTS

1.0 INTRODUCTION ........................................................................................................................................... 4 2.0 ENVIRONMENTAL ASSESSMENT PROCESS .......................................................................................... 5

2.1 Federal and Provincial Cooperation in the Environmental Assessment .......................................................... 5 2.2 Requirement for Provincial Environmental Impact Assessment ...................................................................... 5 2.3 Federal Environmental Assessment ................................................................................................................. 6 2.3.1 Application of the CEAA ............................................................................................................................. 6

2.3.2 Federal Coordination ............................................................................................................................. 7

2.3.3 Scope of Project ............................................................................................................................. 7

2.3.4 Factors ............................................................................................................................. 8

2.4 Scope of the Factors ............................................................................................................................. 8 2.4.1 Spatial Boundaries ............................................................................................................................. 9

2.4.2 Temporal Boundaries ............................................................................................................................. 9

2.5 Determining the Type of Screening EA Process .............................................................................................. 9 3.0 Project-Specific Guidelines for the Environmental Impact Assessment for the proposed receipt and

Processing of MCArthur River ore at the The MCClean Lake Operation ...................................................................... 9 4.0 EIS EXECUTIVE SUMMARY .................................................................................................................... 11 5.0 PROJECT DESCRIPTION ........................................................................................................................... 11

5.1 Project Concept ........................................................................................................................... 11 5.2 Ore Loading, Transport, Receiving, Milling and Waste Management .......................................................... 12 5.2.1 Ore Loading and Transport ...............................................................................................................................

12

5.2.2 Ore Receiving and Milling ........................................................................................................................... 13 5.2.3 Waste Management ........................................................................................................................... 14

6.0 DESCRIPTION OF EXISTING ENVIRONMENT ..................................................................................... 16 6.1 Environmental Database ........................................................................................................................... 16 6.2 Climate, Meteorology and Air Quality .......................................................................................................... 17 6.3 Geology and Hydrogeology ........................................................................................................................... 17 6.4 Surface Hydrology and Water Quality .......................................................................................................... 17 6.5 Aquatic and Terrestrial Ecosystems .............................................................................................................. 17 6.6 Heritage Resources ........................................................................................................................... 18

8.0 PUBLIC AND OCCUPATIONAL HEALTH AND SAFETY ..................................................................... 18 9.0 PUBLIC AND ABORIGINAL INVOLVEMENT ........................................................................................ 19

9.1 Federal Process Requirements ..................................................................................................................... 20 9.2 Proponent Led Public Engagement .............................................................................................................. 20

10.0 IMPACT ASSESSMENT ............................................................................................................................. 21 10.1 General Concepts ........................................................................................................................... 21 10.2 Cumulative Impacts ........................................................................................................................... 22 10.3 Project-Specific Impacts ........................................................................................................................... 22 10.4 Effects of the Environment on the Project ..................................................................................................... 24

11.0 Mitigation and Contingency Planning ........................................................................................................... 24 12.0 MONITORING AND FOLLOW-UP PROGRAMS ..................................................................................... 25

12.1 Monitoring Program ........................................................................................................................... 25 12.2 Follow-Up Program ........................................................................................................................... 26

13.0 DECOMMISSIONING, RECLAMATION AND ABANDONMENT ......................................................... 26 13.1 Conceptual Decommissioning Plan ............................................................................................................... 26 13.2 Reclamation ........................................................................................................................... 26 13.3 Abandonment and Institutional Control......................................................................................................... 27

14.0 SUMMARY .................................................................................................................................................. 27 15.0 REFERENCES .............................................................................................................................................. 27 APPENDIX A - SIMPLE SCREENINGS DETERMINATION ................................................................................. 28 APPENDIX B - PUBLIC PARTICIPATION DETERMINATION ........................................................................... 31

Project-Specific Guidelines Scoping Document - Receipt And Processing of McArthur River Ore at the McClean

Lake Operation

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1.0 INTRODUCTION

The McClean Lake Operation (McClean Lake) is an open-pit uranium mine and mill located in

northern Saskatchewan. The main facilities currently at McClean Lake are a series of completed

open pit mines near Sue Lake (Sue site), the JEB Mill and support facilities (the JEB site) located

near the previously mined-out JEB pit, which has been converted to the JEB Tailings

Management Facility (TMF), various supporting facilities for activities such as water treatment,

and site infrastructure such as roads, electricity distribution and the camp facilities. McClean

Lake is owned by AREVA Resources Canada Inc. (AREVA - 70%), Denison Mines Corp

(22.5%) and OURD Canada Co. Ltd. (7.5%). There is currently a lack of ore for processing at

the JEB Mill, as McClean Lake mining activities ceased in 2008, and high grade ore from Cigar

Lake originally scheduled to commence production in 2007 is unavailable. Cigar Lake has

experienced development delays and is now anticipated to send the first production of uranium

ore slurry (ore slurry) to the JEB Mill in 2013.

In November 2009, AREVA submitted a proposal (Reference 1) to the Saskatchewan Ministry of

Environment-Environmental Assessment Branch (MOE) and the Canadian Nuclear Safety

Commission (CNSC) to transport ore slurry from the McArthur River Mine (McArthur River) to

be milled at McClean Lake (the Project). The transportation of ore slurry would be conducted

using the existing public provincial highway system linking the operations. No construction

activities are associated with this proposal, as both McArthur River and McClean Lake have the

necessary infrastructure in place to support the proposal. This would keep the JEB Mill at

McClean Lake operational while it awaits longer-term ore feed from the nearby Cigar Lake

deposit.

McArthur River is a partnership between Cameco Corporation (operator and 69.805% owner)

and AREVA (30.195%). The McArthur River site consists of an underground mine, one full

service shaft and two ventilation shafts along with numerous surface facilities. This Project will

not result in any changes to infrastructure at McArthur River; it will simply enable AREVA to

process a portion of its share of McArthur River ore at McClean Lake, with the remainder

continuing to be processed at the Key Lake Mill, also a Cameco-AREVA partnership.

The scope of the project was revised in a letter from AREVA April 8, 2010 (Reference 2), and as

now defined by AREVA, the Project is for the production of up to 9 million lbs uranium ore

concentrate (U3O8) at McClean Lake from McArthur River Mine ore slurry. As proposed, this

will occur over a three-year period and will result in approximately two transportation units

leaving daily from McArthur River travelling to McClean Lake for 300 days during the 12

months in advance of successful production from Cigar Lake, and will continue into the first two

years of ramp up during initial production from Cigar Lake to ensure a continuous supply to

McClean Lake.

For the purposes of the environmental assessment (EA), AREVA is the operator of the Project.

AREVA has been informed that the project will require an EA under both The Environmental

Assessment Act (provincial, herein referred to as The Act) and the federal Canadian


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Environmental Assessment Act (CEAA). AREVA is required to conduct an environmental

impact assessment (EIA) and prepare an environmental impact statement (EIS) for technical and

public review. This Project-Specific Guidelines Scoping Document (hereafter referred to as

Project-Specific Guidelines) has been developed with input from provincial and federal experts

to assist AREVA with the conduct of the EIA and the preparation of the EIS.

Several previous environmental assessments have been completed that are relevant to this project

(site characterization). These assessments include:

McClean Lake Mine and Mill (1993 Joint Panel) - the initial approval for the overall

McClean Lake Project, which included the JEB Mill and the overall waste management

system;

Cigar Lake Project (1997 Joint Panel) - the assessment and approval to process Cigar Lake

high grade ore slurry through the JEB Mill Expansion including deposition of tailings to the

JEB TMF & the assessment and approval of the activity of transporting high grade ore slurry

to McClean Lake; and

McArthur River (1997 Joint Panel) - Assessment and approval of the activity of transporting

high grade ore slurry from McArthur River Mine to the Key Lake Operation along highway

914.

The proposed project consists of activities that represent an incremental change to the overall

licensed facility, as the facility has already undergone an EA for the construction and operation of

a high grade circuit and ore receiving infrastructure. Although McArthur River ore has different

physical and chemical properties than ore from Cigar Lake, the milling process and associated

waste management is not anticipated to change.

2.0 ENVIRONMENTAL ASSESSMENT PROCESS

2.1 Federal and Provincial Cooperation in the Environmental Assessment

Under the Canada-Saskatchewan Agreement on Environmental Assessment Cooperation (2005)

federal and provincial EA processes, directed respectively by the CEAA and The Act, are

coordinated for projects with joint federal and provincial jurisdiction, where not limited by

individual statutory or process requirements of the respective processes. Information

requirements of both federal and provincial agencies have been included in these guidelines so

that the information in the EIS should be sufficient to address the environmental concerns of both

the Government of Saskatchewan and the Government of Canada.

Under the agreement, MOE is the lead agency and contact for the coordinated assessment

process. Working with MOE on this project is the CNSC which is the Federal Environmental

Assessment Coordinator (FEAC) and the Responsible Authority (RA) under CEAA.

2.2 Requirement for Provincial Environmental Impact Assessment

The proposal represents a change not consistent with the current EA approvals for McArthur


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River and McClean Lake. Under Section 16(2) of The Act, upon notification of such a proposed

change, determination from the MOE is required. Ministerial decision options under section

16(2) of The Act are:

(a) approve the proposed change and impose any terms and conditions

that are considered advisable;

(b) refuse to approve the change in the development; or

(c) direct the proponent to seek approval for the proposed change in the

manner prescribed in sections 9 to 15 of The Act.

The MOE has determined that application of option (c) is appropriate. AREVA was notified of

this determination in a letter dated 22 March, 2010. As a consequence, AREVA is required to

conduct an EIA of the project and submit an EIS to the MOE.

Should the proposed project be found environmentally acceptable on the basis of the EIS, the

MOE would consider the proponent‟s applications for the necessary modification to the

approvals, permits, and licences that regulate operation of the facilities. The proponent would

also be expected to obtain all necessary approvals, permits, and licences from other regulatory

agencies, as applicable.

The province also has a constitutional obligation to consult with affected Aboriginal peoples

before any decision is made that may adversely impact the ability to successfully exercise Treaty

or Aboriginal rights, particularly the right to hunt, fish and trap. The province will utilize the

EIS, and any other relevant sources of information, to inform itself of the project and any

cumulative impacts of the development on traditional uses, and therefore on Treaty and

Aboriginal rights, to determine the level of provincial Crown consultation required. Mitigation

proposed within the EIS may provide accommodation for any rights affected by the proposed

project.

Consideration of these matters would take place in conjunction with the environmental

regulatory processes that follow the completion of the EA process and issuance of approvals,

licences, and permits that are required prior to the commencement of construction and operation

of a project.

2.3 Federal Environmental Assessment

2.3.1 Application of the CEAA

AREVA‟s proposal would require amending the existing Uranium Mine Operating Licence for

McClean Lake. The amendment of a licence is a power exercised under the authority set out in

subsection 24(2) of the Nuclear Safety and Control Act (NSCA). Subsection 24(2) is listed as a

„trigger‟ under the Law List Regulations established under the CEAA; therefore, there is a

„trigger‟ pursuant to paragraph 5(1)(d) of the CEAA for the proposed project.

The physical works for this proposal are the facilities and associated infrastructure related to the

receipt of ore slurry and the operation of the high grade ore circuit at McClean Lake. The receipt


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and processing of McArthur River ore at McClean Lake is considered a proposed operation in

relation to the physical works. Therefore, the proposed undertakings constitute a „project‟ as

defined in section 2 of the CEAA.

There are no other CEAA „triggers‟, such as funding, being a proponent or disposing of an

interest in land to support the project, pursuant to subsection 5(1) of the CEAA, that involve the

CNSC.

The project is not of a type identified in the Comprehensive Study List Regulations of the CEAA.

Furthermore, the CNSC is not aware of any potential environmental effects and public concerns

to date associated with this project do not warrant referral to a mediator or review panel pursuant

to section 25 of the CEAA. Furthermore, there are no identified exclusions from the conduct of

an EA for this project pursuant to section 7 and Schedule 1 of the Exclusion List Regulations of

the CEAA, nor do any previous EAs apply.

Therefore, pursuant to subsection 18(1) of the CEAA, the CNSC is required to ensure the

conduct of a screening EA and the preparation of a screening report before the proposed licence

amendment can be considered by the CNSC in accordance with the NSCA. AREVA has been

notified of this requirement by the CNSC. The CNSC is delegating the conduct of the EA

technical studies pursuant to subsection 17(1) of the CEAA to AREVA.

2.3.2 Federal Coordination

The CNSC is the only RA for the project, and must ensure that the EA is conducted in

accordance with the provisions of the CEAA. This includes determining the scope of the project,

the factors to be considered in the assessment and the scope of those factors.

Pursuant to the Federal Coordination Regulations under the CEAA, the following federal

departments/agencies with an interest related to their mandate are participating in the review of

this project and, under the CEAA, are Federal Authorities (FAs) in relation to the project:

Fisheries and Oceans Canada (DFO); Environment Canada (EC); Natural Resources Canada

(NRCan); and Health Canada (HC).

2.3.3 Scope of Project

Pursuant to section 15 of CEAA, the Scope of the Project for the proposal to transport ore slurry

from McArthur River to be processed in the JEB Mill at McClean Lake includes:

Loading the ore slurry into IP-2 containers using the existing loadout infrastructure at

McArthur River;

Transport of the ore slurry in “B-train” units consisting of two trailers, each carrying

two IP-2 containers, along existing Provincial Highways 914, 165, 2, and 102/905

(revised scope includes approximately two transportation units leaving McArthur

River per day);

Off-loading the ore slurry at the JEB Mill using existing infrastructure;

Processing the ore at the JEB Mill using existing circuits (including the operation of


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the high grade ore circuit);

Disposal of tailings generated by processing the McArthur River ore at the existing

JEB TMF; and

Management of waste water and other wastes associated with the operation of the JEB

Mill and disposal of tailings in accordance with existing processes and procedures.

No construction activities are associated with this project and milling of the ore slurry at

McClean Lake would be carried out under the operating limits and conditions of the existing

licence and licence documents.

2.3.4 Factors

The scope of the screening assessment under the CEAA must include all the factors identified in

paragraphs 16(l)(a) to (d) of the CEAA and, as provided for under paragraph 16(l)(e), any other

matter that the CNSC requires to be considered. Paragraphs 16(l) (a) to (d) require that the

following factors be included in the screening:

The environmental effects of the project, including the environmental effects of

malfunctions or accidents that may occur in connection with the project and any

cumulative environmental effects that are likely to result from the project in

combination with other projects or activities that have been or will be carried out;

The significance of the effects identified above;

Comments from the public that are received in accordance with the CEAA and its

regulations; and

Measures that are technically and economically feasible and that would mitigate any

significant adverse environmental effects of the project.

2.4 Scope of the Factors

The proposed scope of the factors to be considered by the RA in the screening EA includes the

following list of environmental components likely to be affected. Additional information on

these factors can be found in Section 6 of this document:

Climate, Meteorology and Air Quality;

Geology and Hydrogeology;

Surface Hydrology and Water Quality;

Aquatic and Terrestrial Ecosystems;

Heritage Resources; and

Socio-Economic Issues.

Both the spatial and temporal boundaries will remain flexible during the assessment to allow the

full extent of a likely environmental effect to be considered in the screening as further

information becomes available. For instance, should the results of modelling demonstrate that

there is dispersion of a contaminant that is likely to cause an environmental effect beyond the

boundaries identified, it will be taken into consideration in the assessment.


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2.4.1 Spatial Boundaries

The spatial boundaries used in the EA encompass the geographical areas of the environment that

may be potentially affected by the project, or are relevant to the assessment of cumulative

environmental effects.

Site Study Area

The site study area is the proposed project footprint (i.e. where project activities would be

undertaken – including mine site infrastructure and provincial highways - such as loading

facilities at McArthur River, the JEB Mill, JEB TMF, other applicable McClean Lake facilities,

and applicable provincial highways).

Local Study Area

The local study area is where measurable changes to the environment resulting from the proposed

activities may be anticipated. The geographic boundary will depend on the factor being

considered e.g., a local study area defined for the aquatic environment will differ from that

defined for the atmospheric environment.

Regional Study Area

The regional study area is where the potential effects of this project may interact with the effects

of other projects (including abandoned, operating and/or proposed mines), resulting in the

potential for cumulative effects. The geographic boundary for the regional study areas are also

specific to the factor being considered.

2.4.2 Temporal Boundaries

The temporal boundaries will encompass the entire lifespan of the project (three years from the

start of operation).

2.5 Determining the Type of Screening EA Process

Criteria are used to determine whether screening EAs at the CNSC can follow a simple or

complex track; depending on the potential risk that the proposal would have on the environment

and the anticipated level of public interest. Taking into consideration the criteria and supporting

rationale (Appendix A), the proposed Project was determined to follow the “simple” screening

track. Although it was determined to be a simple screening, the province is the lead agency and

thus the CNSC will support and assist in all provincial public participation processes outlined in

section 9.0.

3.0 PROJECT-SPECIFIC GUIDELINES FOR THE ENVIRONMENTAL IMPACT

ASSESSMENT FOR THE PROPOSED RECEIPT AND PROCESSING OF MCARTHUR


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RIVER ORE AT THE THE MCCLEAN LAKE OPERATION

These guidelines reflect the requirements and issues that have been raised by federal and

provincial officials and their respective acts and regulations regarding the project and identify the

information that should be included in the EIS.

AREVA‟s November 2009 Project Description and subsequent revision letter from April 2010,

noted the following points about the project:

The project would involve existing infrastructure for loading the IP-2 drop-proof slurry

transport containers at McArthur River and off-loading at the McClean Lake JEB Mill. No

construction is required;

The IP-2 units have been in satisfactory service for transport of ore slurry from McArthur

River to the Key Lake Mill for approximately 10 years;

The transport units will consist of truck and two trailers, each carrying two IP-2 containers

(approximately two transportation units leaving McArthur River per day);

The haul route will be from south of the McArthur River mine loadout along Provinical

Highway 914, past Key Lake Mill to the intersection with Provincial Highway 165 south of

Pinehouse Lake. Proceeding east and south on 165 to Highway 2, then north and northeast

on Highway 102 through LaRonge and Missinipe, and from a point a few kilometers west of

Southend north on Highway 905 to McClean Lake.;

Ore will be processed into yellowcake in the McClean Lake JEB Mill, which was designed to

accept ore grading up to 30% U3O8, and is permitted to accept ore from Cigar Lake, which is

similar in grade to McArthur River ore. No modifications to the mill circuits are

contemplated and ore will be processed using existing procedures and in accordance with

operating licence and conditions; and

Tailings will be disposed of in the existing JEB TMF with no changes to operational

procedures.

The EIA should focus on potential environmental impacts which may result from the proposed

hauling of ore slurry from McArthur River to McClean Lake. Processing of the ore at the

McClean Lake JEB Mill, and tailings disposal at the JEB TMF are minor components of the

project as no changes to the licenced operations are anticipated. Information provided in the EIS

which is related to the potential impacts of the ore haul and processing should be complete and in

sufficient detail to allow assessment of the potential impacts. In the event that the project

receives EA approval, the regulatory processes that follow the completion of the EA process and

issue the approvals, licences, and permits that are required prior to the commencement of

operation may require more detailed technical information.

Existing information on environmental parameters which will not be affected by the proposed

project, or information which is cited to provide context for the discussion of potential impacts,

may be referenced and provided in summary form.

These guidelines should not be considered as either exhaustive or restrictive, as concerns other

than those already identified could arise during the investigations associated with the EIA.


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Reference to the MOE General Guidelines for Conducting an Environmental Impact Assessment

and to guidance materials provided by the Canadian Environmental Assessment Agency

(http://www.ceaa-acee.gc.ca/012/newguidance_e.htm ) is recommended. In addition, MOE and

the CNSC are prepared to provide advice and assistance throughout the EIA with regard to the

identification of environmental concerns and appropriate assessment methodologies.

4.0 EIS EXECUTIVE SUMMARY

An executive summary of the EIS is required. It should briefly summarize and cross-reference

the EIS under the following topic areas:

Description of the project;

Purpose of and need for the project;

Environmental effects of the project, including the potential

spills/malfunctions/accidents;

Any cumulative environmental effects that are likely to result from the project in

combination with other projects or activities that have been or will be carried out;

Technically and economically feasible mitigation measures;

The significance of the environmental impacts; and

Comments from the public and AREVA‟s responses.

The executive summary, which can be under separate cover, should avoid the use of technical

terms and jargon. To enhance involvement of northern Saskatchewan residents, First Nations

and Métis in the public participation process, the executive summary should be translated into

each aboriginal language, Cree and Dené, and made accessible in video and/or audio form.

5.0 PROJECT DESCRIPTION

5.1 Project Concept

The EIS should provide a comprehensive description of the proposed project, including the

purpose of and need for the project. A description of how current operations will change as a

result of the implementation of the proposed project, if approved, is needed so that the changes

that would occur at McArthur River and McClean Lake, and along the proposed haul route, and

the potential environmental impacts of the project, can be placed in context with the existing

environmental conditions.

All stages of the project, such as loading, transporting, off-loading, processing, tailings and waste

disposal, and any associated maintenance should be described. The EIS should clearly identify

where the proposed project differs from the existing approvals at McArthur River and McClean

Lake. This information is to be supported by technical data in sufficient detail and scope to

determine whether the potential environmental impacts of the proposed project differ from those

of the existing licensed activities. Any differences should be assessed for significance.


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Generally, the EIS should include the following information:

Ownership of the project and project components;

Location, using local and regional maps with identifiable features;

Status and map of surface lease and active mineral dispositions relevant to the project;

The need for the project;

Description of proposed project (including project life, dimensions, plans);

Alternative means of accomplishing the project. A recently proposed road link between

McArthur River and Cigar Lake should be discussed, if applicable (including AREVA‟s

plans to start using this new road as soon as it becomes available);

Contingency plans if the Cigar Lake operation does not begin production as currently

anticipated in 2013;

Materials and power requirements;

Sourcing of materials;

Anticipated schedule for implementation;

Estimated manpower and skill requirements;

Conventional/radiological occupational health and safety considerations;

Emergency measures/contingency plans and procedures;

Technical issues and new technologies specific to the project;

A description of the potentially affected environment;

Potential contaminant releases due to accidental spills of ore slurry along the haul road

and their impact to human health and the environment; and

Technically and economically feasible monitoring and mitigation measures.

5.2 Ore Loading, Transport, Receiving, Milling and Waste Management

5.2.1 Ore Loading and Transport

The EIS should contain a description of the procedures necessary to transport ore slurry from

McArthur River to the McClean Lake JEB Mill. It is noted that the project description is

thorough and includes much of this information and may be sufficient for the purpose of the EIS.

This description should include:

Loading procedures at the existing McArthur River loading facility;

Radiation protection and analysis of expected radiation exposures of drivers of ore

slurry trucks;

A description of emergency response plans for on-road incidents, including

emergency response team location(s) or mustering point(s), worst-case response

times, procedures for emergency road closure, procedures for protection of water

supplies, and interaction with or assistance from local fire departments. Exposure

projections associated with emergency conditions should reference the maximum

uranium concentrations anticipated;

Detailed discussion of past experience using IP-2 containers to haul ore slurry


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between the McArthur River Mine and Key Lake Mill, including frequency and

impact of major and minor incidents;

Details on road standards and procedures followed for past projects compared to

proposed standards and procedures to be followed for this project In particular, the

conditions of the portions of the haul route maintained by Cameco (914 extension), on

which the IP-2 units have traveled for more than 10 years should be compared to the

remainder of the haul route, with respect to general road conditions, surface stability,

safe speeds etc.;

Details on driver training, including radiation and emergency response training;

The trip is estimated to take 17 hours each way. The EIS should provide information

on the number of drivers per unit and scheduling, including assurance of appropriate

rest and information on the staging of transport, including details regarding fuel stop

requirements and allowances for in-trip vehicle maintenance;

Details on driver protection including the driver‟s radiation exposure, the need for

radiation protection for the cab if the driver remains in the cab for rest periods or

unplanned delays, including but not limited to vehicle breakdown and winter storm,

and comparison of driver exposure levels compared to those for the haul between

McArthur River and Key Lake; and

Procedures to be followed when winter storms, road washouts, forest fires etc. make

all or part of the route impassable.

The EIS should contain a comprehensive description of the ore haul with reference to current

regulatory standards for transportation of radioactive substances. The description should discuss:

Container design and safety criteria;

Trucks, haul cycles, and safety procedures, including traffic control measures for the

route, dust control, and severe weather driving restrictions;

Radiological and non-radiological occupational health and safety procedures and

training for truck drivers;

Potential for vehicle and wildlife collisions;

Noise disturbance effects on wildlife distribution and habitat use;

Contingency and emergency management planning for the prevention of, and

response to, accidents and ore spills; and

Any additional safety procedures or spill control measures required for stream

crossing sites.

5.2.2 Ore Receiving and Milling

Currently, McClean Lake has only been assessed and approved to process high grade ore from

Cameco‟s Cigar Lake Mine. Both the Cigar Lake ore deposit and the McArthur River ore

deposit are high-grade deposits. The 1995 Cigar Lake EIS provided details on off-loading of ore

slurry and processing of high-grade uranium ore at the JEB Mill. Because uranium grades and

physical properties of ore from Cigar Lake and McArthur River are similar, the proponent


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anticipates that receipt and processing of ore from McArthur River will be carried out in a

manner very similar to the procedures anticipated in the 1995 EIS for receipt and processing of

Cigar Lake ore. While reference may be made to the 1995 document, the EIS for the current

project should clearly identify any changes in process, equipment, or procedures needed to

process ore from McArthur River as opposed to Cigar Lake.

Information provided in the EIS should address:

Off-loading procedures at the JEB Mill off-load facility;

Container washing procedures, including treatment and disposal of wash water;

Ore storage and blending procedures;

A comparison of the physical and chemical properties of Cigar Lake ore and

McArthur River ore, including previously assessed, and if identified, new

contaminants of concern;

Proposed changes to mill practices necessitated by chemical or physical

characteristics of the McArthur River ore;

Implications for current environmental and/or worker health and safety as well as

radiation protection programs; and

Expected doses to workers from receiving, off-loading and milling ore slurry from

McArthur River.

5.2.3 Waste Management

The EIS should include detailed information regarding any changes in quality, quantity, and

potential environmental impacts associated with management programs for all wastes which

would be generated, specifying the waste streams that will remain on-site and the waste streams

that will be moved to another facility relative to past McClean Lake operations and planned for

Cigar Lake. Any anticipated change in mill processing that may be necessary if levels of

contaminants of concern (e.g. Cu, Sn, Ni, As, Co, Cd) are higher in the McArthur River ore than

in the Cigar Lake ore, should be discussed, including any long-term significant impacts to the

JEB TMF.

The EIS should focus on changes at McClean Lake necessitated by the project. Relevant

information related to any potential changes to the treatment of liquid effluent, sewage, surface

drainage, atmospheric emissions, and tailings disposal management should be addressed.

Tailings Disposal

The project proposal states that no changes to the existing tailings preparation process in the JEB

Mill or to the JEB TMF are required to accommodate the milling of the McArthur River ore at

McClean Lake. However, for the purposes of the EA the EIS should provide the basis for the

statement in the project proposal including:

Evaluation of impacts of this project on the capacity of the JEB TMF;

The yearly and cumulative expected volumes of tailings to be generated from this


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project; and

Contingency plans for unexpected variation in volume, hydraulic performance, and

predicted geochemical properties of the tailings.

Any anticipated changes resulting from the proposed project related to environmental protection

procedures during operations, water balance, and containment of potential contaminants in the

tailings disposal system following reclamation and decommissioning should be described.

Liquid Effluent

Any anticipated changes in water balances should be provided. Any water anticipated to not meet

Saskatchewan’s Mineral Industry Environmental Protection Regulation limits, the Metal Mining

Effluent Regulations (MMER) of the federal Fisheries Act and/or CNSC licence requirements

will require treatment prior to release.

The EIS should demonstrate that the project will not lead to contaminants and loadings in aquatic

receiving systems in excess of those predicted from currently licensed activities. The EIS should

identify locations (e.g., Universal Transverse Mercators (UTMs)) where objectives/guidelines are

not met to provide an indication of the potential migration of effects beyond those expected from

currently licensed activities.

The EIS should address any anticipated changes to:

Quantity and quality of liquid effluents;

Treatment processes, including total loadings for treatment and process chemicals;

Quantity, quality and final disposal of slimes, sludges and precipitates from sumps,

sedimentation ponds and treated water holding ponds (monitoring ponds) and facility

features and handling procedures to minimize spills and environmental effects from

disposal; and

Anticipated radiation dose to any human receptor resulting from radiological

contaminants in the liquid effluents.

Atmospheric Emissions

The EIS should address any anticipated changes to:

Quality and quantity of all airborne emissions (e.g., SOx, NOx, dust, radon and

radionuclides) emanating from the mill;

Operational monitoring programs for air quality parameters; and

Anticipated radiation dose to any human receptor resulting from radiological

contaminants in atmospheric emissions.


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6.0 DESCRIPTION OF EXISTING ENVIRONMENT

6.1 Environmental Database

The project will be carried out over several locations, including the McArthur River ore loading

facility, Provincial Highways 914, 165, 2, and 102/905, the JEB Mill, JEB TMF, and associated

infrastructure and other waste management systems at McClean Lake.

The EIS should contain a description, in terms of local and regional scales, of the existing

environment which may be reasonably affected by the transporting and accident scenarios along

the haul route. A similar description should be provided for the receiving and processing of

McArthur River ore slurry at McClean Lake and all associated processes, including waste

management, and the extent that changes are anticipated as a result of the project.

The database should include a complete and accurate description of the current status of those

environmental parameters that are regulated by federal and provincial agencies at McClean Lake

that may be affected by the project.

All environmental data that are included in the EIS should be collected using accepted

methodologies and be available to the MOE and the CNSC. These methodologies should be

consistent in order to allow comparative use of the data and facilitate ecosystem management.

Engineering or geoscience components of the EIA should be conducted in accordance with the

Engineering and Geoscience Professions Act of Saskatchewan.

Should changes/additions to the existing database be needed as a result of the project, the

database in the EIS should provide a sound basis for not only the EIA of the project, but also the

operational environmental monitoring and post-operational decommissioning, reclamation, and

abandonment. The environmental data should contribute to, and be in a form compatible with,

the existing environmental effects monitoring database for the assessment of potential effects on

a regional scale.

Therefore, the data in the EIS should satisfy the following criteria:

(i) That the baseline data accurately describe the existing environment that may be

affected by the project as proposed;

(ii) Any new data should provide a sound basis for comparative monitoring and the

development of sound decommissioning, reclamation and abandonment

procedures. This would include the establishment of reference and potential

exposure stations that will allow for the assessment of any impacts that may occur

as a result of the project; and

(iii) That the EIS be self-supporting, in terms of data availability and presentation.

Existing data on environmental parameters that will not be affected by the proposed project, but

are cited to provide context for the discussion of potential impacts, may be referenced or

provided in summary form.


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6.2 Climate, Meteorology and Air Quality

The current databases of climatic, meteorological, and air quality information, including dust,

radon and gamma radiation data for McClean Lake should be referenced. If available, similar

information from any meteorological stations along the haul route should be referenced. Any use

of off-site data must be thoroughly discussed and qualified with an understanding of local and

regional variability and the geographic locations of on-site and off-site meteorological stations.

Specific information regarding emissions from haul trucks over the course of the project and

implications of the additional traffic load that this project would mean to the proposed haul route

should be included.

6.3 Geology and Hydrogeology

The EIS should contain a description of the regional geology and hydrogeology of the McArthur

River and McClean Lake sites and the haul route sufficient to discuss the implications of the

proposed project. Relevant information on surficial geology/geomorphology should be discussed

in terms of any potential effects on the project (e.g., ground stability, slumping, and acid/metal

release).

Geological features such as faults, fractures, shears, seismic activity or hydrogeologic

characteristics (e.g., artesian conditions), that may have an impact on the project should be

identified and their significance described.

The EIS should discuss any anticipated changes in the current hydrologic conditions, where

appropriate e.g., tailing storage and settling ponds. Any anticipated changes in quantity, quality,

and flow rates of groundwater likely to be affected by the proposed project should be provided.

6.4 Surface Hydrology and Water Quality

Regional scale data on watershed areas, drainage patterns, characteristics of water bodies

(streams, rivers, lakes or ponds), flow rates, bathymetry, water volume (lakes and ponds), and

water quality should be included to a level of detail sufficient to assess consequences of potential

accidents or malfunctions. Particular attention should be paid to community water intakes from

surface water bodies along the haul route, including the number and locations of water intakes,

distance from the haul route, quality and quantity of intake waters, and any other surface water

that may interact with water intakes through groundwater.

6.5 Aquatic and Terrestrial Ecosystems

The EIS should provide relevant information on aquatic and terrestrial ecology along the haul

route to the extent that is required to assess consequences of potential accidents or malfunctions.

Information on aquatic and terrestrial species designated as “rare”, “endangered”, “threatened”

and “species of special concern” under the Species at Risk Act and the Saskatchewan Wildlife Act

should be included. Refer to the Committee on the Status of Endangered Wildlife in Canada

(COSEWIC) - www.cosewic.gc.ca. Relevant data on potentially affected soil and vegetation,

http://www.cosewic.gc.ca/


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including lichen, rare and endangered flora located along associated roads and rights-of-way

should be described. Analyses of selected soil and vegetation parameters should provide

information to describe any changes that may result from an accidental spill/malfunction.

The EIS should identify the species within the terrestrial and aquatic environments that are

important components of food chains leading to, and used by, people living in the region. Any

anticipated changes to the status of these species in the impact area in regards to their relative

abundance and any measured levels of contaminants in their tissues, especially heavy metals and

radionuclides, should be documented.

6.6 Heritage Resources

In the EIS, the proponent should note that following their review of the proposal, the Heritage

Resources Branch of the Saskatchewan Ministry of Tourism, Parks, Culture and Sport has

indicated that since no new construction is required, they see no potential impact to heritage

resources. The proponent should confirm these conclusions with local First Nations and Métis

during the conduct of the EIA.

7.0 SOCIO-ECONOMIC ISSUES

The EIS should provide a description of employment, skill levels, training/retraining, jobs

targeted for Northerners and contractor opportunities associated with the project. Commitments

to potential local, regional, and Saskatchewan suppliers should be noted.

It is noted that, in the proposal, AREVA re-affirms its commitment to hiring northern contractors

and creating opportunities for northern businesses, thus ensuring further economic benefits for

local people. Any existing or new measures to be taken in order for AREVA to fulfill this

commitment should be described.

8.0 PUBLIC AND OCCUPATIONAL HEALTH AND SAFETY

The EIS should address both conventional and radiological public and worker health and safety.

The EIS documentation should include:

Calculations of annual radiation exposures to truck drivers, loadout and off-load employees;

Calculations of annual radiation exposures to residents of the communities along the haul

routes;

Potential non-radionuclide hazards to workers in airborne dust and programs that are, or will

be in place to monitor these hazards;

Potential radiation doses to mill workers as a result of any anticipated changes to current

milling operations;

A statement of any radiological design changes that will be required as a result of this project;

Details on how the current source term throughout the facility will be affected as a result of

this project; and


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Any changes as a result of the proposed project to engineered controls, programs, Action

Levels, and a Radiation Protection Code of Practice proposed to control worker radiation

doses and intake of radioactive prescribed substances.

The EIS should discuss any anticipated changes to existing radiation protection programs

including changes to the routine radiological monitoring schedule, changes to the dosimetry

monitoring strategy, changes in radioactive contamination control programs, and changes in

training programs. The EIS should discuss the development of any additional training modules

for environmental instrumentation, protection, and awareness and how AREVA‟s commitment to

the ALARA (As Low As Reasonably Achievable) principle of radiation protection will be

implemented.

Programs should meet the regulatory requirements of The Occupational Health and Safety Act,

The Occupational Health and Safety Regulations, The Saskatchewan Mines Regulations (2003)

and the NSCA Radiation Protection Regulations.

The EIS should include information on worker health and safety as a result of malfunctions and

accidents.

9.0 PUBLIC AND ABORIGINAL INVOLVEMENT

Local and regional residents and interested organizations should be fully informed of the

proposal to transport ore from McArthur River to McClean Lake. Potentially affected Aboriginal

peoples must be provided with the information they need with respect to the project and its

potential impacts. The proponent must ensure that it engages with Aboriginal peoples who may

be affected by the project and who have asserted or established Aboriginal rights, Aboriginal title

or treaty rights. It is noted that, in the proposal, AREVA commits to a stakeholder engagement

program as part of the EA.

The EIS should describe the proponent‟s program for consultation with northern residents,

residents from First Nations, Métis and other northern communities. Public involvement and any

concerns raised should be documented in the EIS and their significance evaluated. The

documentation should provide information regarding the demographics of the communities that

were part of the public involvement program and the level of consultation that took place with

these communities.

The program should promote a broader understanding of both the potential impacts of the project

and the monitoring programs and results. Efforts should be made to involve the public in issue

identification (e.g., contribution of traditional knowledge to the determination of Valued

Ecosystem Components (VECs)), and problem resolution. Elements of the plans for public

information/engagement should provide a basis for discussion of enhancement of regional

business and employment opportunities. This information should include a concise description

of AREVA‟s public engagement program.


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As interest in the proposed project may extend beyond the project area, AREVA should be

prepared to provide project information to, and address issues identified by, persons residing

outside of the project area.

MOE will use the information provided by the proponent on their stakeholder engagement

efforts, along with the information provided regarding the potential of the proposed activities to

affect Treaty or Aboriginal rights to inform its decisions regarding Crown Duty to Consult

obligations with respect to the proposal.

9.1 Federal Process Requirements

A public registry for the project assessment has been established. This includes identification of

the project assessment in the Canadian Environmental Assessment Registry (CEAR), which can

be accessed on the Internet web site of the agency (www.ceaa.gc.ca). The CEAR reference

number for the project is 10-01-53814.

In accordance with section 18(3) of the CEAA, the CNSC is responsible for determining the need

for and level of public participation for a project. Based on the public participation criteria and

rationale (Appendix B), it was determined that the proposed project requires public participation.

The CNSC will perform the following public participation activities:

Post notice of commencement of EA on both the CNSC website and the CEAR within 2

weeks of a determination (completed);

Post notice of availability of the draft Project-Specific Guidelines Scoping Document and

allow a 30-day review and comment period (completed); and,

Post notice of availability of draft EA Screening Report and allow a 30-day review and

comment period.

As the MOE is the lead for this EA, the project is also subject to the provincial public

participation process. The CNSC will support the provincially-led public review of the EA

Project-Specific Guidelines, EIS, and Technical Review Comments by posting a notice of

availability of all documents on the CNSC website and the CEAR. Additionally, the public and

Aboriginal groups will be provided an opportunity to comment on the CNSC EA Screening

Report. The CNSC and MOE may consider a joint public review period for the EIS, Technical

Review Comments, and EA Screening Report.

The CNSC is satisfied that the public participation processes to be implemented by the proponent

and the province with the support of the CNSC will be sufficient. The public participation

process will provide the public with a variety of opportunities to be informed and provide input

at all stages of the study. The process will also allow the public to react to proposals in order to

influence recommendations and decisions and to be informed of all decisions.

9.2 Proponent Led Public Engagement

Regional residents or organizations should be fully informed of the proposed project. It is stated

in the project proposal that AREVA intends to carry out the following public engagement


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activities:

Identify interested or „key‟ stakeholders, and their communication and information needs.

A stakeholder list will be developed and maintained throughout the EA and regulatory

processes;

Inform all stakeholders about the progress of the project, with respect to milestones and

key activities, and the means of raising questions and comments;

Provide opportunities for stakeholders to exchange information, and identify and discuss

any concerns they may have;

Document and maintain a record of all communication processes and outcomes;

Identify and document issues, comments and concerns raised by stakeholders related to

the project and AREVA in general, as they arise;

Develop and document all appropriate responses to address stakeholder comments,

issues, concerns and questions as they arise; and

Ensure comments and responses are available to the public through the reporting

requirements associated with the EA and regulatory process to illustrate how issues have

been addressed through the various regulatory processes.

10.0 IMPACT ASSESSMENT

10.1 General Concepts

The EIA process must address the factors identified in the introduction and provide the

information necessary to determine the likelihood of significant adverse effects and whether the

benefits to the Province of the proposed activity justify the environmental costs.

The environmental effects of the project, and their significance, must be described, including the

environmental effects of malfunctions or accidents that may occur in connection with the project.

Any cumulative environmental effects that are likely to result from the project in combination

with other projects or activities that have been, or will be, carried out must be evaluated.

Residual environmental impacts which cannot be mitigated during operation and

decommissioning should be identified and their significance discussed. Environmental effects

are defined in CEAA as:

(a) any change that the project may cause in the environment, including any change it

may cause to a listed wildlife species, its critical habitat or the residences of individuals of that

species, as those terns are defined in subsection 2(1) of the Species at Rick Act,

(b) any effect of any such change referred to in paragraph (a) on

(i) health and socio-economic conditions,

(ii) physical and cultural heritage,

(iii) the current use of lands and resources for traditional purposes by aboriginal

persons, or

(iv) any structure, site or thing that is of historical, archaeological, paleontological

or architectural significance, or


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(c) any change to the project that may be caused by the environment, whether any such

change occurs within or outside Canada.

10.2 Cumulative Impacts

The EIS should discuss whether existing environmental conditions, including other uranium

developments in the area, such as the Midwest and Caribou projects, will influence the project.

The discussion should address whether the project-specific effects of the proposed project,

combined with the impacts from existing and planned developments in the region will result in,

or contribute to, any regional or cumulative environmental effects.

The Canadian Environmental Assessment Agency guidance documents Operational Policy

Statement OPS-EPO/3-1999 Addressing Cumulative Environmental Effects Under the Canadian

Environmental Assessment Act, and Cumulative Effects Assessment Practitioners Guide should

also be consulted regarding the scope of cumulative impacts to be evaluated in the EIS.

10.3 Project-Specific Impacts

The EIS should document and evaluate the significance of any negative impacts of the project on

the environment. To provide context, the EIS should discuss whether historic exploration and

industrial development activities have influenced the current status of the environment, fisheries,

wildlife, or resource use at McArthur River or McClean Lake or along the proposed haul route.

The EIS should focus on the significance of incremental effects resulting from changes to the

currently licensed activities needed to support the project.

Impact predictions should be categorized according to defined criteria, and should be as specific

and quantitative as possible.

The EIS should assess the potential effects of any incremental environmental changes on human

health or the use of lands, waters and resources for traditional purposes by aboriginal persons and

on the quality of any country foods that may be harvested. Potential entry of contaminants of

concern in liquid and airborne waste streams, (e.g., radionuclides, heavy metals), into food chains

and the terrestrial or aquatic environment should be described to the extent that they are above

levels predicted for currently licensed activities.

The EIS should discuss the proposed project with respect to greenhouse gases and other climate

change parameters.

The quantity and quality of treated effluents are critical issues for environmental protection. The

EIS should address any changes anticipated in effluent quality or quantity at McArthur River

and/or McClean Lake as a result of the project. If the project is anticipated to change the

currently licensed activities and/or operating limits and conditions, the EIS should include the

following:

Any anticipated incremental changes in quality and quantity of effluents to be released to

the environment as a result of the project, and their contribution to current assessments of


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waste loadings and dispersion in the aquatic receiving system(s). The dispersion of the

effluent plume should be used to identify potential exposure sites for monitoring. The

EIS should identify where contaminant levels would, and would not, meet Saskatchewan

Surface Water Quality Objectives and Canadian Water Quality Guidelines downstream

from the facility and provide an evaluation of any environmental impacts;

Any changes to existing points for control, monitoring and final discharge to the

environment;

Any anticipated incremental changes to short and long term aquatic environmental effects

of continued loading of chemical parameters on receiving waters and predicted mixing

effect zone as a result of the project;

An estimate of the spatial extent of sediment contamination in a worst case scenario due

to an accident and/or malfunction, by providing suspended particle concentrations and

water to particle partitioning coefficients for each contaminant, and the range of settling

velocities ascribed to suspended particles in each of the receiving water bodies identified;

Potential incremental impacts to benthic invertebrates, fish, wildlife and plants based on

contaminant transport modeling results;

Use of abiotic and biotic monitoring programs in evaluating the aquatic and terrestrial

environmental effects of this project. This should include the selection of potential

reference and exposure locations;

To the extent that they are relevant to the assessment of potential incremental

environmental effects, results of any studies currently being undertaken of in-lake and in-

stream water quality/sediment conditions and biota, and the merits of developing

procedures, including biological or statistical indices/measures, for the tracking of

changes to aquatic health;

Predictions of maximum contaminant concentrations and total contaminant loadings to

streams or other water bodies in worst case scenario of an accidental/malfunction ore spill

along the haul route; and

Potential impacts to water quality, sediment quality, fish and fish habitats in streams and

other water bodies in a worst case scenario due to an accidental/malfunction ore spill

along the haul route.

Potential impacts at any stream crossing location along access roads should be identified and

appropriate mitigative measures proposed. The Saskatchewan Watershed Authority (SWA)

noted in their review of the project proposal that the trucks will cross more than two hundred

streams, pass by nearly four hundred other water bodies and pass through several communities.

The assessment of risk as a consequence of an accidental ore spill should consider spills in or

near communities, community water sources, and water bodies in general.

SWA also noted several licensed surface and groundwater projects along the haul route, and the

potential for unlicensed water withdrawals. The proponent should contact Bart Oegema at 306-

694-3957, SWA‟s contact for emergency planning, to obtain existing receptor survey information

for the corridor on either side of the proposed haul route.

Contaminant loadings and predictions of contaminant concentrations to the terrestrial


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environment adjacent to the haul route in a worst case scenario (i.e. spill to a wetland or other

known sensitive habitat within 100 m of the haul route with known sensitive terrestrial receptors

of concern, such as a rare amphibian, plant, bird and mammal) as a consequence of an ore spill

due to malfunctions/accidents, should be provided. Seasonal scenarios (i.e. spring, summer, fall

and winter) and effects to terrestrial receptors and emergency clean-up techniques should be

addressed.

The potential interaction of an accidental ore spill with human receptors through direct contact

(i.e. inhalation, skin contact) and indirect contact (i.e. ingestion of impacted drinking water

(groundwater and surface water sources), country foods) both within existing communities and

individual residences along the haul route and as a consequence of chancing upon an accident in

remote sections of the haul route should be provided.

The potential impacts from all contaminant sources should be combined to provide a cumulative

impact assessment. If the project is anticipated to change currently licensed activities or

operating limits and conditions, an assessment of post-decommissioning contaminant loadings to

the environment should be discussed in the context of criteria for the design of operational

monitoring programs and decommissioning, reclamation, and abandonment planning.

10.4 Effects of the Environment on the Project

The assessment must also take into account how the environment could adversely affect the

project; for example severe weather. Guidance can be found on the CEAA website: The

Federal-Provincial-Territorial Committee on Climate Change and Environmental Assessment

2003. Incorporating Climate Change Considerations in Environmental Assessment: General

Guidance for Practitioners http://www.ceaa-acee.gc.ca/default.asp?lang=En&n=A41F45C5-1

This part of the assessment will be conducted in a step-wise fashion, similar to that described for

the foregoing assessment of the project effects. The possible important interactions between the

natural hazards and the project will be first identified, followed by an assessment of the effects of

those interactions, the available mitigation measures, and the significance of any remaining likely

adverse effects on the project.

11.0 MITIGATION AND CONTINGENCY PLANNING

The EIS must identify and describe technically and economically feasible mitigation measures

that may be applied to each likely adverse environmental effect. All mitigation measures

described throughout the EIS must be documented in the mitigation section.

The EIS should also document mitigation and contingency plans which would be implemented in

the event of any potential containment failures, spills, malfunctions, accidents or inadvertent

waste releases associated with the project. The proponent should identify commitments for

adaptive management measures to be implemented should monitoring or follow-up programs

identify unreasonable or unforeseen environmental impacts.

http://www.ceaa-acee.gc.ca/default.asp?lang=En&n=A41F45C5-1


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Any changes to mitigation, monitoring and conceptual de-commissioning at McArthur River

and/or McClean Lake should be discussed. The EIS should discuss any changes necessary to

existing adaptive management, mitigation measures and current contingency planning at

McClean Lake to manage activities associated with the project.

Although the detailed mitigation and contingency plans would be designed in consultation with

regulatory agencies through regulatory processes and would be subject to periodic review during

operations, the EIS should document mitigation and contingency plans which would be

implemented in the event of containment failures, spills, malfunctions, accidents, or inadvertent

waste releases.

If needed as a result of modification to the currently licensed activities, a hazard analysis or other

risk-based approach should be used to identify situations where mitigative measures may be

needed. If an engineering or administrative control solution is not technically or economically

feasible, then a contingency plan should be developed.

12.0 MONITORING AND FOLLOW-UP PROGRAMS

As a result of the various EA approvals in conjunction with Federal and Provincial operating

licences, both McArthur River and McClean Lake initiated and maintain monitoring and/or EA

follow-up programs that are subject to regular reporting requirements.

The EIS should identify the need for, and requirements of, any follow-up assessment or

monitoring programs beyond those currently in place as they relate to the proposed project.

12.1 Monitoring Program

The EIS should discuss any changes to the existing monitoring programs at McArthur River and

McClean Lake as a result of the project, including:

Monitoring programs for any potential environmental impacts, including potential

contaminant loadings to plant and animal species, that are considered relevant VECs;

Monitoring programs to confirm ground water and surface water quality in the vicinity of

the JEB TMF;

Commitments for operational response procedures to be followed should monitoring

programs identify environmental changes or unforeseen/unacceptable impacts (e.g.,

changes to mill process or effluent treatment); and

The Tailings Optimization and Validation Program (TOVP) for the JEB, which occurs

every 5 years.

Monitoring should not only ensure compliance with regulatory requirements but should also

allow the systematic audit of the EIA process, specifically the accuracy of predictions and the

adequacy of proposed mitigation measures. The monitoring programs, in verifying the

environmental impact predictions, should confirm the design criteria for reclamation and

abandonment objectives and planning procedures.


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If changes to the existing monitoring programs are required, the program should incorporate and

build upon the work undertaken in fulfillment of the environmental effects monitoring

requirements of the Metal Mining Effluent Regulations of the federal Fisheries Act.

Development of monitoring programs should be made with reference to Saskatchewan

Environment‟s guidelines document: “Environmental Monitoring Guidelines (For Operational

Monitoring at Uranium and Gold Mining and Milling Operations in Saskatchewan) and to the

Saskatchewan Environment and Public Safety, Mines Pollution Control Branch, March 31,

1989".

12.2 Follow-Up Program

If changes to the existing federal follow-up program are required as a result of the project, the

program should include a detailed scope of the change in program together with schedule and

reporting milestones. Changes to the existing follow-up program plan should be described in the

EIS in sufficient detail to allow independent judgement as to the likelihood that it will deliver the

type, quantity and quality of information required to reliably verify predicted effects (or absence

of them), confirm EIS assumptions and confirm effectiveness of mitigation. The EIS should

include a description of the objectives of the follow-up program, the elements of the plan

required to achieve the objectives, the implementation plan and reporting commitments.

The CNSC would ensure the implementation of any required follow-up program through the

licensing and compliance process. The CEAA follow-up may be a component of the larger

monitoring program, but should be specifically defined and presented.

13.0 DECOMMISSIONING, RECLAMATION AND ABANDONMENT

Although changes to the detailed plans for decommissioning, reclamation, and abandonment

would be developed in consultation with regulatory agencies through regulatory processes, and

would be subject to periodic review during operations, the EIS should provide descriptions of

any changes to these plans resulting from the project.

13.1 Conceptual Decommissioning Plan

The EIS should briefly describe the existing conceptual decommissioning plans for McArthur

River and McClean Lake, and outline any changes necessitated by the proposed project.

13.2 Reclamation

Reclamation planning concepts which should be included in the EIS are described in MOE‟s

Northern Mine Decommissioning and Reclamation Guidelines, EPB 381. These guidelines

include criteria for cleanup of soils contaminated by chemical or radioactive materials.

For the purposes of the EA, the EIS should provide any changes required to the existing

reclamation plan as a result of the project. Supporting documentation for proposed changes to

existing reclamation programs that are necessitated by the proposed project and incremental to

those currently in place for McArthur River and McClean Lake should be included in the EIS.


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13.3 Abandonment and Institutional Control

The EIS should include any changes necessitated by the ore haul project to the proposed criteria

for abandoning the McClean Lake and McArthur River sites and associated infrastructure.

Provisions for the long-term institutional control should be discussed, including, but not limited

to:

Record keeping or archiving that fully describes past operations, decommissioning plans

and assessments, final configurations, and release verification;

Post-abandonment site monitoring and verification;

The need for passive site management;

Land controls; and

Long term financial liabilities for monitoring, care, and maintenance, or contingency

remediation.

14.0 SUMMARY

The EIS should provide a concise, complete statement of the anticipated net environmental costs

and benefits of the proposed transport of ore slurry from McArthur River Mine to be processed in

the JEB Mill at McClean Lake, in both the short and long-terms. The discussion should include,

if possible, any intangible costs and benefits that cannot be expressed in economic terms. To

satisfy federal and provincial requirements, this statement must include conclusions specifically

on whether the project is likely to cause significant adverse effects on the environment.

15.0 REFERENCES

1. Letter, T. Van Lambalgen (AREVA) to M. Leblanc (CNSC), “Application by AREVA

Resources Canada Inc. (“AREVA”) to Amend McClean Lake Operating licence for the

Receipt and Processing of McArthur River ore at the McClean Lake Operation”.

November 5, 2009. E-DOC: 3457365

2. Letter, T. Van Lambalgen (AREVA) to L. Casterton (CNSC) & L. Kelley (SMOE),

“Receipt and Processing McArthur River Ore at the McClean Lake Operation: Change to

Purpose and Project Schedule Revised”. April 8, 2010. E-DOC: 3533777


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APPENDIX A - SIMPLE SCREENINGS DETERMINATION

Record of Determination

Criteria Evaluation Questions for Simple

Screenings

Yes/True Uncertain No/False

1. The site is well characterized, as are its

programs.

2. The proposed project is related to an existing

licensed facility.

3. The proposed project represents an incremental

change to the overall facility.

4. The environmental performance of the existing

licensed activities meets CNSC expectations.

5. The proposed project is based on technology

that is known to the proponent and CNSC staff.

6. The proposed project would only require

mitigation measures with which the proponent

has a demonstrated familiarity, and/or that are

considered standard technology within the

industry.

7. The proposed project does not introduce

project-environment interactions that cannot be

mitigated with standard or proven technology.

8. Based on potential project-environment

interactions, the proposed project is not likely

to pose any significant adverse effects on the

health of workers and the public, cumulative

effects, or those that may arise as a result of

accidents or malfunctions.


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E-DOC: 3539014 29

Rationale and additional comments to support determination:

1. The site is well characterized as it has been subject to a number of EAs. The

construction and operation of the McClean Lake Mine and Mill was approved in

1993 by the Joint Federal-Provincial Panel on Uranium Mining Developments in

northern Saskatchewan. In 1997, the Cigar Lake Project was approved by the Joint

Panel, which included the approval to expand the McClean Lake Mill (JEB Mill),

process high grade ore from Cigar Lake and deposition of tailings in the JEB

Tailings Management Facility. Other EAs (e.g., Mining Sue E ore proposal) have

been conducted for mining and milling activities that have been undertaken at the

McClean Lake site, which have contributed to site characterization.

2. The proposed project is located on an existing licensed facility.

3. The proposed project consists of activities (i.e., the receipt and processing of high

grade ore) that represent an incremental change to the overall licensed facility. This

is considered an incremental change as the facility has already undergone and EA

for the construction and operation of a high grade circuit and ore receiving

infrastructure. Although McArthur River ore has different physical and chemical

properties than ore from Cigar Lake, the milling process and associated waste

management is not anticipated to change.

4. CNSC staff conducted a review of the Environmental Protection Program area to

assess the adequacy with respect to the CNSC S-296 standard, Environmental

Protection Polices, Programs and Procedures for a Class I Nuclear Facility and

Uranium Mines and Mills. It was concluded that the environmental policy,

identification of environmental aspects, the use of objectives and targets, roles and

responsibilities, communication, emergency preparedness and response, and

documentation processes meet expectations.

AREVA is required to submit a Monthly Environment Report to satisfy the

conditions of Saskatchewan Ministry of the Environment (MOE) Approval to

operate Pollutant Control Facilities IO-205 (expires August 31, 2010), Approval to

Temporarily Close It-39 Midwest project, Permit to operate Waterworks #‟s

00050626-01-00, 00050627-01-00, 00050628-01-00 (expires December 31, 2013);

CNSC Operating Licence UMOL-MINEMILL-McCLEAN.00/2017 (expires June

30, 2017); and the Metal Mining Effluent Regulations (MMER).

5. CNSC staff is familiar with the technology being presented in this project as it has

already been subject to an EA and has been licensed with satisfactory performance.

All project activities are based on technology that is known to AREVA and no

construction activities are associated with this project. The project is proposed to

be carried out using existing ore receiving, processing and waste management

infrastructure.


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E-DOC: 3539014 30

6. The receipt and processing of high grade ore from Cigar Lake has already been

assessed for McClean Lake. Although the physical and chemical properties of

McArthur River Ore are different than Cigar Lake ore, the waste outputs are not

expected to change. Therefore, AREVA is familiar with all mitigation measures

required for the project activities and these mitigation measures are considered

standard technology within the industry. Mitigation & operational procedures

under the existing licence are not expected to change as a result of this project.

7. Any new project-environment interactions are expected to be adequately mitigated

with standard and/or proven technology. However, as the outputs associated with

the receipt and processing of McArthur River ore are not expected to change from

what was previously assessed, no new project-environment interactions are

anticipated.

8. At this stage of the EA, it appears that this project is not likely to cause significant

adverse effects on the health of workers and the public; cumulative effects; or those

that may arise as a result of accidents or malfunctions. The EA will identify all

potential project-environment interactions and confirm that the project is not likely

to cause significant adverse effects.

As a result of the scan above, is a simple screening appropriate in the circumstances?

YES or NO


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E-DOC: 3539014 31

APPENDIX B - PUBLIC PARTICIPATION DETERMINATION

Evaluation of Criteria

Assessment Criteria None Low Moderate High

1. There is an indication of existing or likely

public interest in :

a. the type of project

b. the location of the project or

c. the ways the project might affect the

community.

2. The stakeholders who may be interested have a

history of being involved.

3. The project could generate conflict between

environmental and social or economic values of

concern to the public

4. The project could be perceived as having the

potential for significant adverse environmental

effects (including cumulative environmental

effects and effects of malfunctions and accidents).

5. There is potential to learn from community

knowledge or Aboriginal traditional knowledge.

6. The direct and indirect environmental effects of

the project and their significance are uncertain.

7. The project has not been subject to other public

participation processes of appropriate scope and

coverage that would meet CNSC objectives.

Count number of check marks in each column 1 3 3 0

Multiply by: x 0 x 1 x 2 x 3

Total for each column is: 0 3 6 0

Add totals for an overall score of: 9


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E-DOC: 3539014 32

Rationale for determination

Criterion 1.

a) AREVA conducted a number of focused group meetings with northern community members

and leaders (including Métis), businesses, organizations and regulators. Most questions and

concerns were in relation to transportation logistics and safety risks associated with the ore slurry

haul from McArthur River Mine to the McClean Lake Operation, with fewer comments and

concerns submitted in relation to receiving and processing of high grade ore. Furthermore, the

Northern Saskatchewan Environmental Quality Committee (NSEQC) issued a resolution (e-docs

#3543483) expressing concerns around the transportation logistics involved in AREVA‟s

proposal. Therefore, there is an indication of existing public interest in the type of project.

b) During the public hearing held on April 30, 2009 regarding the licence renewal for the

McClean Lake Operation, five oral interventions and one written intervention were submitted.

This is an indication of existing public interest in the location of the project. Comments and

concerns raised at AREVA-led focused group meetings, as well as the NSEQC resolution, are

also indications of existing public interest in the location of the project.

c) As a result of AREVA-led focused group meetings, the public has an interest in the project, as

transportation logistics may affect local communities. This view was also expressed in the

NSEQC‟s resolution. The receiving and processing of high grade ore would be contained

entirely on the existing McClean Lake site and is not anticipated to affect local communities.

This sentiment was reflected in the few comments and concerns submitted during focused group

meetings in regard to receiving and processing high grade ore. However, as transportation is a

key activity in this project, the public does have an interest in the project as a whole and in the

ways that the project may affect local communities.

Criterion 2.

Five oral interventions and one written intervention were presented by stakeholders during the

April 2009 McClean Lake Operation licence renewal hearing. This is an indication that

stakeholders who may have an interest in activities related to the McClean Lake Operation have a

history of being involved. Similarly, the CNSC and SMOE are currently conducting a

cooperative EA concerning AREVA‟s proposed Caribou Project at McClean Lake. Three

submissions were received on the Project-Specific Guidelines and no comments were submitted

on the EA Screening Report. Although few comments were received, there is still an indication

of stakeholders having a history of being involved.

Criterion 3.

The receiving and processing of high grade ore is not anticipated to generate conflict between

environmental and social or economic values of concern to the public as previous EAs have been

conducted regarding this activity (e.g., Cigar Lake Joint Panel 1997, Construction of Cigar Lake

Mine 2004 and the Sue E Project 2005). The transportation of high grade ore slurry from

McArthur River to Key Lake was also assessed by a Joint Panel in 1997 (McArthur River

Project). However, AREVA‟s proposed transportation to McClean Lake was not assessed, and

based on preliminary focused group meetings led by AREVA, there is a potential the project

could generate conflict between environmental and social or economic values of concern to the


Lake Operation

E-DOC: 3539014 33

public. This sentiment was also expressed in the NSEQC‟s resolution.

Criterion 4.

The public and Aboriginal groups were involved in the 1997 Joint Panel processes for both Cigar

Lake and McArthur River. The receiving and processing of high grade ore from Cigar Lake at

the McClean Lake Operation were considered in this Panel. This Panel process, in conjunction

with the comments received during AREVA-led focused group meetings does not indicate that

the public could perceive the project as having potential for significant adverse environmental

effects associated with receiving and processing of high grade ore. Although the 1997 Joint

Panel (McArthur River Project) assessed both cumulative environmental effects and effects of

malfunctions and accidents associated with transportation of high grade ore slurry on provincial

highway 914, a number of concerns were raised regarding transportation logistics at AREVA-led

focused group meetings. The concerns may reflect the change in transportation route, as the

route proposed by AREVA has not been previously assessed. Therefore, although the Joint Panel

determined there were no significant environmental effects in relation to transportation of high

grade ore slurry along provincial highway 914, the transportation logistics associated with

AREVA‟s proposed project could be perceived as having the potential for significant adverse

environmental effects.

Criterion 5.

Local communities and Aboriginal groups were involved in previous EAs and on-going licensing

performance reviews of both sites and were provided the opportunity to share relevant

community and traditional knowledge. However, as the proposed transportation route was not

considered in any previous EA, there may be a potential to learn from community and Aboriginal

traditional knowledge.

Criterion 6.

Receiving and processing of high grade ore from Cigar Lake was assessed in the 1997 Joint

Panel (Cigar Lake Project). Although the ore from McArthur River has different physical and

chemical properties, there is no uncertainty with potential direct or indirect environmental

effects. Direct and indirect environmental effects associated with transportation of high grade

ore was assessed in the 1997 Joint Panel (McArthur River project). Therefore, there is minimal

uncertainty regarding direct and indirect environmental effects relating to transportation.

However, the McArthur River Project did not include the socio-economic environment

associated with AREVA‟s new proposed transportation route. Therefore, there is the potential

for uncertainty in regards to direct and indirect socio-economic environment effects associated

with the project.

Criterion 7.

The project will be subject to the Province of Saskatchewan‟s public participation processes.

This includes public consultation on the EA Project-Specific Guidelines, the EIS and the

Technical Review Comments. Technical Review Comments are issues identified by the SMOE,

CNSC staff and identified FAs during their review of the EIS, and are to be addressed by

AREVA. AREVA will make all necessary revisions based on the Technical Review Comments,


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E-DOC: 3539014 34

and a revised EIS will be submitted. The revised EIS and Technical Review Comments are

subject to the provincial public review process. The CNSC will co-ordinate with the provincial

public participation processes, and post appropriate notices concerning public participation on

the Canadian Environmental Assessment Registry and the CNSC website. Furthermore, the

CNSC will conduct a public review period on the EA Screening Report, which may occur

concurrently with the public review of the EIS and Technical Review Comments. CNSC staff

will revise the EA Screening Report based on comments received, prior to submission to the

Commission for decision.

Additional reasons, if any, why public participation is or is not appropriate for

this project:

1.

2.

As a result of the scan above, is public participation appropriate in the circumstances of this

screening-level EA?

Yes or No

If yes, indicate the level of participation required, based on the tabulated score.

None

0 to 2

Low

3 to 7

Moderate

8 to 14

High

15 to 21

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