project-specific guidelines for the ... guidelines for the preparation of an environmental impact...

PROJECT-SPECIFIC GUIDELINES

FOR THE

PREPARATION OF AN ENVIRONMENTAL IMPACT STATEMENT

CIGAR LAKE WATER INFLOW MANAGEMENT PROJECT

CAMECO CORPORATION

These guidelines were prepared by Saskatchewan Environment and the Canadian Nuclear Safety Commission to assist Cameco Corporation with the environmental impact assessment

of the proposed Cigar Lake Water Inflow Management Project.

The guidelines, in draft form, were made available for public review From June 25, 2009 to July 28, 2009

Province of Saskatchewan and Department of Environment

December 2009

Project Specific Guidelines – Cigar Lake Water Inflow Management Project

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Table of Contents

1.0 INTRODUCTION ............................................................................................................1 2.0 FEDERAL AND PROVINCIAL COOPERATION IN ENVIRONMENTAL

ASSESSMENT .................................................................................................................1 3.0 REQUIREMENT FOR PROVINCIAL ENVIRONMENTAL IMPACT ASSESSMENT2 4.0 FEDERAL ENVIRONMENTAL ASSESSMENT ..........................................................3

4.1 Application of the Canadian Environmental Assessment Act.................................. 3 4.2 Federal Coordination ................................................................................................ 4 4.3 Scope of Project ........................................................................................................ 4 4.4 Factors....................................................................................................................... 4 4.5 Scope of the Factors.................................................................................................. 5

4.5.1 Spatial Boundaries ................................................................................................ 5 4.5.2 Temporal Boundaries............................................................................................ 5

5.0 PROJECT-SPECIFIC GUIDELINES FOR THE ENVIRONMENTAL IMPACT ASSESSMENT OF THE PROJECT ................................................................................6

6.0 EXECUTIVE SUMMARY ..............................................................................................6 7.0 PROJECT DESCRIPTION...............................................................................................7

7.1 Project Concept......................................................................................................... 7 7.2 Project-Specific Information Requirements ............................................................. 8

7.2.1 Project Overview .................................................................................................. 8 7.2.2 Mine Water ........................................................................................................... 8 7.2.3 Mine Dewatering .................................................................................................. 9 7.2.4 Treatment of Mine Water...................................................................................... 9 7.2.5 Release of Treated Mine Water Effluent to the Environment .............................. 9

7.3 Waste Management................................................................................................... 9 8.0 DESCRIPTION OF THE EXISTING ENVIRONMENT..............................................10

8.1 Environmental Database ......................................................................................... 10 8.2 Climate, Meteorology and Air Quality ................................................................... 11 8.3 Geology and Hydrogeology.................................................................................... 11 8.4 Surface Hydrology and Water Quality ................................................................... 11 8.5 Aquatic and Terrestrial Ecology ............................................................................. 12

9.0 SOCIO-ECONOMIC ENVIRONMENT........................................................................13 9.1 Occupational Health and Safety ............................................................................. 13 9.2 Heritage Resources ................................................................................................. 13

10.0 PUBLIC INVOLVEMENT ............................................................................................15 11.0 ENVIRONMENTAL Impact Assessment ......................................................................16

11.1 General Concepts .................................................................................................... 16 11.2 Regional Impacts .................................................................................................... 16 11.3 Project-Specific Impacts ......................................................................................... 17 11.4 Mitigation and Contingency Planning .................................................................... 19 11.5 Effects of the Environment on the Project.............................................................. 20

12.0 MONITORING...............................................................................................................20


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13.0 DECOMMISSIONING, RECLAMATION AND ABANDONMENT..........................21 13.1 Conceptual Decommissioning Plan ........................................................................ 21 13.2 Reclamation ............................................................................................................ 22 13.3 Financial Assurance................................................................................................ 22 13.4 Abandonment and Institutional Control ................................................................. 22

14.0 SUMMARY....................................................................................................................23


1.0 INTRODUCTION

The Cigar Lake Uranium Development (Cigar Lake) is a uranium mining operation operated by Cameco Corporation (Cameco). Cigar Lake received provincial approval under The Environmental Assessment Act (the act) on 27 March, 1998 to mine uranium ore and transport the ore to McClean Lake Uranium Development for processing. The approval was issued after reviews by the Saskatchewan environmental assessment (EA) review process and the independent, public, Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan (Joint Panel). Since that time environmental management of construction and operational activities at Cigar Lake has been subject to provincial regulatory approvals, permits and licences issued by the Saskatchewan Ministry of Environment (MOE), Environmental Protection Branch, Industrial, Uranium and Hardrock Mining Unit under The Mineral Industry Environmental Protection Regulations of The Environmental Management and Protection Act. Cameco is currently licensed by the Canadian Nuclear Safety Commission (CNSC) under licence UMCL-MINE-CIGAR.021/2009, which was issued by the CNSC under the authority of the Nuclear Safety and Control Act (NSCA). The licence authorizes Cameco to construct a uranium mine at Cigar Lake and to maintain the facilities necessary to support this construction. In December 2008, Cameco submitted a proposal to MOE and the CNSC to modify the current water inflow management system at Cigar Lake to handle increased quantities of water inflow. The proposed activities may require a minor adjustment to the current Cigar Lake surface lease boundaries. Cameco has been informed that their proposal will require an EA under both the act (Saskatchewan) and the Canadian Environmental Assessment Act (CEAA). Cameco is required to conduct an environmental impact assessment (EIA) and prepare an environmental impact statement (EIS) for technical and public review. These project-specific guidelines have been prepared to assist Cameco with the conduct of the EIA and the preparation of the EIS. The EIS also will form the basis of an EA screening report that is required for a federal EA. The screening report will be made available for public review at the same time the Province makes the EIS and Technical Review Comments available for public review.

2.0 FEDERAL AND PROVINCIAL COOPERATION IN 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

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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 the Province of Saskatchewan, Environmental Assessment Branch, is the lead agency and contact for the assessment of the project.

3.0 REQUIREMENT FOR PROVINCIAL ENVIRONMENTAL IMPACT ASSESSMENT

The proposal to effectively manage the increased quantities of water inflow experienced and expected during the construction and operation of Cigar Lake (the project) was not part of the previous EA review1 conducted by the provincial government and the Joint Panel on Cigar Lake. Consequently, the project represents a change to Cigar Lake that does not conform to the terms and conditions of the March 1998 Cigar Lake approval under the Act. In Saskatchewan, a change to an approved development is subject to the provisions of section 16 of the act. Cameco been directed to seek approval for the proposed change to Cigar Lake (i.e., the project), pursuant to section 16(2) (c) of the Act. Under section 16(2) (c) Cameco is required to conduct an EIA of the project and prepare and submit an EIS to the Minister of Environment. Should the project be found environmentally acceptable, MOE would consider the proponents application for the necessary approvals, permits and licences that regulate construction and operation of the facility. MOE has identified the following regulatory requirements:

• an application and permit to Construct Pollutant Control Facilities and an amendment to the Approval to Operate IO-183 will be required pursuant to The Mineral Industry Protection Regulations under The Environmental Management and Protection Act (2002);

• Cameco may require a permit to alter shoreline as per Section 36 of The Environmental Management and Protection Act (2002); and

• a Forest Product Permit pursuant to The Saskatchewan Forest Resources Management Act & Regulations is required for Cameco to remove or disturb any forest products that are incidental to the project activity.

The Province also has a constitutional obligation to consult with affected First Nations and Métis communities 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 Crown consultation required. Comments received from First Nations and Métis communities during the public

1 Canadian Nuclear Safety Commission. June 2004. Environmental Assessment Screening Report for the Construction and operation of the Cigar Lake Uranium Mine Project.

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review period for the draft Project-Specific Guidelines have been considered in the finalization of the guidelines for the EIS. In addition, the EIS will require the documentation of the current use of lands and resources concerning the study area for traditional purposes by First Nations and Métis, the project, the cumulative impacts of the project on these uses, and possible mitigation strategies to avoid or reduce these impacts. Mitigation proposed within the EIS may provide accommodation for any rights impacted by the proposed project. Any outstanding resolution of these matters would take place in conjunction with the environmental 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 construction and operation of a project.

4.0 FEDERAL ENVIRONMENTAL ASSESSMENT

4.1 Application of the Canadian Environmental Assessment Act

Cameco’s proposal would require approval to deviate from the requirements of an existing licence that would require the approval of the Commission pursuant to section 24(2) of the NSCA. The granting of an approval under a licence condition constitutes a “trigger” under paragraph 5(1)(d) of the CEAA because in giving an approval, the CNSC would be taking an action “under a provision prescribed pursuant to paragraph 59(f)” of the CEAA. In addition, Fisheries and Oceans Canada (DFO) may be required to issue a subsection 35(2) Fisheries Act authorization for the project. A subsection 35(2) Fisheries Act authorization also constitutes a “trigger” under paragraph 5(1)(d) of the CEAA. In addition, Fisheries and Oceans Canada (DFO) and Transport Canada (TC) may also have a ‘trigger’ pursuant to the Fisheries Act and the Navigable Waters Protection Act, respectively. Therefore, there is a ‘trigger’ pursuant to paragraph 5(1)(d) of the CEAA. This proposal involves the following undertakings in relation to a physical work (the water management system at the Cigar Lake mine): modifications to the effluent treatment release facilities and the construction of two discharge pipelines. Therefore, there is a “project” as defined in section 2 of the CEAA. The project is not of a type identified in the Comprehensive Study List Regulations of the CEAA, nor is the CNSC aware of any potential environmental effects or public concerns that would 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 of the CEAA which includes Schedule 1 of the Exclusion List Regulations, 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 approval decision can be made pursuant to the NSCA for the requested approval. Cameco has been notified of this requirement by the CNSC. The CNSC would delegate to Cameco the conduct of certain technical studies pursuant to

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subsection 17(1) of the CEAA.

4.2 Federal Coordination

The CNSC is a Responsible Authority (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: Environment Canada (EC); Natural Resources Canada (NRCan); Indian and Northern Affairs Canada (INAC); Health Canada (HC); DFO and TC. DFO and TC may also be RAs for this assessment and their roles will be clarified as more information becomes available.

4.3 Scope of Project

Pursuant to section 15 of CEAA, the Scope of the Project for the proposal includes: • construction of two new parallel discharge pipelines that would deliver treated water

to the same discharge point into Seru Bay of Waterbury Lake. The smaller discharge pipeline will transfer treated routine water from routine inflows, while in non-routine circumstances, a combination of the two pipelines would be used as required;

• modifications to the current water handling and effluent treatment release facilities. This is limited to the upgrading and installation of pumps and piping as necessary to connect the proposed discharge pipelines to the existing water treatment facility infrastructure and ponds;

• operation of the Project; and • decommissioning of the Project.

4.4 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

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• measures that are technically and economically feasible and that would mitigate any significant adverse environmental effects of the project.

With the discretion allowed for in paragraph 16(l)(e) of the CEAA, the CNSC requires that the following additional factors be included in the environmental assessment:

• the need for, and requirements of a follow-up program in respect of the project; and • the capacity of renewable resources that are likely to be significantly affected by the

project to meet the needs of the present and those of the future.

4.5 Scope of the Factors

4.5.1 Spatial Boundaries

The geographic study areas for this screening encompass the areas of the environment that may reasonably be expected to be affected by the project, or which may be relevant to the assessment of cumulative environmental effects. Study areas encompass all relevant components of the environment including the people, non-human biota, land, water, air and other aspects of the natural and human environment. Site Study Area The site study area is the area where the physical works, such as the proposed pipeline, would be located. Local Study Area The local study area is the area where measurable changes to the environment resulting from the proposed activities may be anticipated. The local study area for this proposal is the land surface that would be disturbed by construction of the pipeline and all access ways, and Seru Bay where effluent would be released. Regional Study Area The regional study area is Waterbury Lake, where the effects of this project may interact with the effects of additional operating or proposed mines results in potential for cumulative effects at the regional level.

4.5.2 Temporal Boundaries

The timeframe for the assessment encompasses the construction period for the project, as well as the operating life and decommissioning period for the Cigar Lake mine (approximately 40 years).

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5.0 PROJECT-SPECIFIC GUIDELINES FOR THE ENVIRONMENTAL IMPACT ASSESSMENT OF THE PROJECT

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. The EIA should focus on potential new or additive environmental impacts that may result from the implementation of the project and on potential alterations to the existing levels of environmental impacts that are currently regulated at Cigar Lake. Information provided in the EIS that is related to the potential impacts of the project should be complete and detailed. Existing information on environmental parameters at Cigar Lake that will not be affected by the 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. Reference to MOE’s General Guidelines for Conducting an Environmental Impact Assessment2 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.

6.0 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; • environmental effects of the project, including 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; • identification of uncertainties in regards to the project elements and/or environmental

impacts of the project, including those of a chemical, physical, and/or radiological nature;

• significance of the environmental impacts; • need for, and the requirements of, any follow-up program in respect of the project;

2 Saskatchewan Environment Environmental Assessment Branch. January 1996. The Saskatchewan Environmental Assessment and Review Process.

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• productivity of renewable resources that are likely to be significantly affected by the

project; and • comments from the public and Cameco’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 or audio form.

7.0 PROJECT DESCRIPTION

7.1 Project Concept

The EIS should provide a brief, yet comprehensive, description of the existing Cigar Lake uranium development. This description of the current operations, together with a description of the proposed Project, is needed so that the changes that would occur to Cigar Lake as a consequence of the Project, and the potential environmental impacts of the project, could be placed in context with the existing environmental conditions. Relevant details of prior EAs, Status of environment reports, Environmental Effects Monitoring reports etc. need to be reviewed and incorporated where appropriate. Any current activities at Cigar Lake that may link with the project (e.g., interim decommissioning or remediation), should be identified and evaluated. All stages of the project – such as siting, construction, operation, maintenance, decommissioning and abandonment - should be described. The EIS should clearly identify where the project differs from the information and commitments contained in prior EAs. This information is to be supported by technical data in sufficient detail and scope to enable an accurate assessment of the potential environmental impacts of the project. Generally, the EIS should include the following information:

• ownership of the Cigar Lake mine and its components; • location of the Cigar Lake mine, using local and regional maps with identifiable

features; and • status and map of surface lease and active mineral disposition relative to the Cigar

Lake mine. Any changes to the operations or infrastructure at the Cigar Lake site that would be necessary to accommodate the project should be described and the potential effects on the environment assessed (e.g., materials; water and water management; roads and infrastructure; monitoring systems and maintenance plans; and decommissioning plans).

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7.2 Project-Specific Information Requirements

7.2.1 Project Overview

An overview of the proposed project should include the following, where relevant: • description of proposed project including project life, dimensions, plans; • anticipated schedule for construction and implementation; • conventional/radiological occupational health and safety considerations; • technical issues and new technologies specific to the project; • description of the potentially affected environment; • contaminant releases and their impact on the environment; • technically and economically feasible mitigation measures; and • monitoring programs that support adaptive management, emergency measures and

contingency plans and procedures. To satisfy the information needs of TC in light of the Navigable Waters Protection Act, the EIS should include the following information:

• proposed works associated with the Project that involves building in, on, over, through or across any navigable waterway could result in the interference of the public right to navigate; and

• description of known waterway users, including known vessel use on affected waterways. As well, all waterways affected by proposed works (new or changes to existing infrastructure) in, on, over, under, through or across any waterway should be discussed in the EIS. This would also include any temporary works that may impede vessel passage and safety.

The EIS should include the following:

• appropriately scaled maps depicting where the existing waterways and in-water works are located;

• physical characteristics of the waterway (e.g., length, width, depth, seasonal flow, fluctuations);

• photographs of the proposed work locations (e.g., crossings, upstream and downstream views); and

• detailed drawings (plan and profile views) and proposed construction schedules and methods of the proposed in-water works, both permanent and temporary.

7.2.2 Mine Water

The EIS should provide a detailed description of the mine inflow waters anticipated under routine and non-routine operating conditions at the Cigar Lake mine including:

• volumes; • flow rates; • chemistry, including conductivity and contaminants of potential concern (e.g.,

radium, molybdenum, copper, selenium); and • potential variability of mine inflow parameters.

The EIS should also discuss the hydrogeological model used to determine the groundwater

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characteristics at Cigar Lake and the estimation of potential maximum mine water inflows.

7.2.3 Mine Dewatering

The EIS should describe mine dewatering procedures, including; • sumps, pumps, pipelines and their respective capacities; • treatment capabilities for collection ponds and reagent addition buildings, including

settling times and any potential seasonal variation; • transport of mine inflow water to surface water treatment facilities; • quantity, quality and final disposal of slimes, sludges and precipitates from sumps;

and • contingency plans for malfunctions/accidents/emergency releases of mine water

inflows.

7.2.4 Treatment of Mine Water

The EIS should address in detail: • existing and proposed water treatment circuits for routine and non-routine mine water

inflows and their respective capacities; • treatment processes, including total loadings for treatment and process chemicals; • proposed pipelines/surface works; • quantity, quality and final disposal of slimes, sludges and precipitates from sumps,

sedimentation ponds and treated water holding ponds (monitoring ponds); and • contingency plans for malfunctions or accidents.

Mine water treatment should be discussed in the context of minimizing contaminant loadings to the environment using the best technically and economically feasible technologies.

7.2.5 Release of Treated Mine Water Effluent to the Environment

Project-specific information should include: • siting and construction of proposed pipelines and surface works; • siting and construction of pipelines in Seru Bay; • diffusion/dispersion mechanisms at the end of discharge pipes in Seru Bay; • anticipated quality and quantity of treated mine water to be released to the

environment; • proposed points for control, monitoring and final discharge to the environment; and • contingency plans for malfunctions or accidents.

7.3 Waste Management

Previous reviews of Cigar Lake have addressed waste management issues. The EIS should identify if the project would require changes to the existing management programs for solid, liquid and gaseous wastes at the Cigar Lake site.

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Detailed information regarding the anticipated quality, quantity and potential environmental impacts associated with any changes to existing management programs for liquid effluent, sewage, surface drainage and atmospheric emissions should be provided. Relevant information would include:

• quality and quantity of all airborne emissions (e.g., SOx, NOx, dust, radon and radionuclides) and operational monitoring programs for air quality parameters;

• domestic and industrial waste (types, volumes and disposal methods and waste minimization to be employed); and

• surface diversion/drainage works, collection, storage, sampling, treatment and release of surface runoff and design criteria for all drainage and leachate/runoff collection systems.

Any water not meeting Saskatchewan's Mineral Industry Environmental Protection Regulation limits, the Federal Metal Mining Effluent Regulations and the CNSC license limits will have to be treated prior to release.

8.0 DESCRIPTION OF THE EXISTING ENVIRONMENT

8.1 Environmental Database

The EIS should contain a description of the existing environment which may be reasonably affected by the project and allow an evaluation and prediction of the potential environmental effects 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 the approved Cigar Lake operations and 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 MOE and the CNSC. These methodologies should be consistent in order to allow comparative use of the data and facilitate ecosystem management. 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:

• that the baseline data accurately describe the existing environment that may be affected by the project as proposed;

• that the data provide a sound basis for comparative monitoring and the development

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of sound decommissioning, reclamation and abandonment procedures; and • that the EIS be self-supporting, in terms of data availability and presentation.

It is noted, however, that comprehensive databases of environmental information have been compiled at Cigar Lake as a consequence of regulatory activities that have been completed, or are current, at the site. Existing data on environmental parameters that will not be affected by the project, but are cited to provide context for the discussion of potential impacts, may be referenced or provided in summary form.

8.2 Climate, Meteorology and Air Quality

Cigar Lake’s current database of climatic, meteorological and air quality information, including radon and gamma radiation data, should be referenced. A brief summary of this information, including relevant dust and noise data, should be provided. Any implications for the project arising from on-site conditions should be discussed (e.g., effects on hydrologic balances). 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. The EIS should include the current status of Cigar Lake with respect to climate change parameters.

8.3 Geology and Hydrogeology

The EIS should contain a description of the geology and hydrogeology of the Cigar Lake site sufficient to discuss the implications of the 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 material weathering). Any hydrogeologic characteristics that may have an impact on the project should be identified and their significance described. Relevant Cigar Lake site groundwater information, including results of any groundwater contaminant transport modelling and model sensitivity analyses, should be provided for both operational and post-decommissioning periods. The EIS should discuss whether previous groundwater modeling predictions for the Cigar Lake site have been verified by current operational monitoring data.

8.4 Surface Hydrology and Water Quality

The EIS should discuss the surface hydrology and water quality in the Aline Creek and the Waterbury Lake watersheds potentially affected by the proposal and include data on watershed areas, drainage patterns, flow rates and water quality. Parameters discussed should include:

• mean annual discharge and seasonal variation; • water column profiles for temperature and oxygen in Seru and Longyear Bays;

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• erosion potential in the Aline Creek watershed; and • discharge and full bank flow in Aline Creek.

Any potential for interaction between surface water and groundwater systems should be discussed. Should this project be approved, works including the construction and operation of waste water disposal systems, water diversions, surface and groundwater uses and any earthwork in the construction and operation of works, would require approval by the Saskatchewan Watershed Authority.

8.5 Aquatic and Terrestrial Ecology

Relevant information on aquatic and terrestrial ecology likely to be affected by the project should be included in the EIS. Sufficient physical, chemical, and biological data should be obtained to quantify any gains or losses in the productivity of fish habitat that may result from the proposed project. The information should address:

• description of plant communities, including species lists, dominant species and densities for canopy, understory and ground cover;

• soil profiles, including thickness of organic and mineral horizons and buffering capacities;

• numbers and important population characteristics of any potentially affected fish species (e.g., sensitive habitats), and the possible effects on aquatic resources;

• hydrology, bathymetry and limnology of any potentially affected waters, including pre-development concentration of contaminants in sediments;

• current sediment quality in Seru Bay and potentially affected areas of Waterbury Lake;

• fish habitat use in Seru Bay according to fish species, life stage, time of year, etc., including for Lake Trout;

• spring/fall spawning investigations in Seru Bay; • numbers and characteristics of any potentially affected wildlife species (e.g.,

woodland caribou, moose, bear, aquatic and riparian furbearers), avifauna, sensitive habitats, resident/migrant populations and species with commercial and/or subsistence values;

• plant or animal species considered rare, endangered or threatened, (refer to Committee on the Status of Endangered Wildlife in Canada (COSEWIC) - www.cosewic.gc.ca); and

• results of any previous studies of the Aline Creek/Seru Bay/Waterbury Lake aquatic systems predicting impacts to benthic invertebrates, fish, wildlife and plants based on contaminant transport modeling.

The EIS should include an enhanced aquatic baseline characterization of Seru Bay and Waterbury Lake with emphasis on required data to support contaminant dispersion and deposition modeling and characterization of the current selenium distribution in abiotic and

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


biotic environmental components. Relevant data on potentially affected soil and vegetation, including rare and endangered flora, for the project area and associated roads and rights-of-way should be described. Analyses of selected soil and vegetation parameters should establish operational monitoring baseline conditions for potential contaminants and/or contaminant accumulation. Sample site selection should be sensitive to prevailing wind direction. 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. The status of these species in the impact area in regards to their relative abundance and any measured levels of contaminants in their tissues, including heavy metals and radionuclides, should be documented. Any salvage or disposal of merchantable and unmerchantable timber, slash and debris is to be described. The EIS should describe fire prevention and suppression programs, including wildfire.

9.0 SOCIO-ECONOMIC ENVIRONMENT

The EIS should provide a description of current employment, skill levels, training/retraining, jobs targeted for Northerners and contractor opportunities at Cigar Lake and identify where any changes may occur as a consequence of the project. Reference to commitments under the current Surface Lease Agreement should be made. Commitments to potential local, regional and Saskatchewan suppliers should be noted. It is noted in the proposal that Cigar Lake is currently operated with the intent of maximizing employment and business participation for residents of Northern Saskatchewan. Cameco’s commitment to provide employment, economic and training opportunities to First Nations and Métis peoples and contractors is set out in its Cigar Lake Surface Lease and Human Resource Development Agreements.

9.1 Occupational Health and Safety

Previous reviews of the Cigar Lake site have addressed both conventional and radiological worker health and safety. The EIS should identify if the project would require changes to the existing programs for conventional and radiological worker health and safety at these sites. The Mine Safety Unit, Saskatchewan Advanced Education, Employment and Labour, notes that all of the occupational health and safety regulations currently applicable to Cigar Lake, including the Occupational Health and Safety Act, the Occupational Health and Safety Regulations, and the Saskatchewan Mines Regulations (2003), will be applicable to the project. When the project commences it would be monitored by routine inspection.

9.2 Heritage Resources

As noted in the 2008 proposal previous heritage resource impact assessment reviews of the Cigar Lake site conducted in 1983 and 1984 uncovered several archaeological items at three different sites near the Waterbury Lake exploration camp. The EIS should include a

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summary

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of the 1983 and 1984 heritage reviews and report on any subsequent heritage resource reviews conducted to assess the potential heritage resource impacts of the project. The Heritage Resources Branch, Saskatchewan Ministry of Culture, Youth and Recreation, requests that Cameco submits the proposal to the Branch for heritage resource review given an anticipated high heritage resource potential. Should the land requirements for the project change an additional evaluation of heritage potential would be required.

10.0 PUBLIC INVOLVEMENT

Regional residents or organizations should be fully informed of the project. It is noted in the proposal that Cameco has presented the project proposal to members of the Athabasca Environmental Quality Committee at the Cigar Lake site in July 2008 and to the full Northern Environmental Quality Committee in La Ronge in December 2008. The EIS should describe the program for consultation with northern residents, particularly residents from First Nations, Métis and the northern communities defined as impact communities for Cigar Lake. Public involvement and any concerns raised should be documented in the EIS and their significance evaluated. Where possible, the documentation should provide information regarding the demographics of the communities that were part of the public involvement program and the level of participation in the meetings and discussion that took place in 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/consultation should provide a basis for discussion of enhancement of regional business and employment opportunities. It is noted that there are no active Treaty Land Entitlements, Surface Claim Selections or Indian Reserves in the area proposed for the project. This information should include a concise description of Cameco’s current public consultation program at Cigar Lake, including any regular communication promoted with the Athabasca Working Group and the Athabasca Environmental Quality Committee. As interest in the development may extend beyond the project area, Cameco should be prepared to provide project information to, and address issues identified by, persons residing outside of the project area. 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),

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which can be accessed on the Internet web site of the agency (www.ceaa.gc.ca). The CEAR reference number for the project is 09-01-46666. It is expected that Cameco will:

• provide information through community meetings or various media so that the public can be informed and participate effectively;

• receive information and comments from the public; • discuss issues and clarify positions and concerns with the public; • build consensus among key groups or individuals particularly affected by the project

(i.e., the Environmental Quality Committees); and • inform participants of results and decisions.

The CNSC will also consult the public and Aboriginal groups during the review and decision making process for the screening report. This will involve an opportunity for the public to review and comment to CNSC staff on the draft Screening Report.

11.0 ENVIRONMENTAL IMPACT ASSESSMENT

11.1 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, and (b) any effect of any such change on health and socio-economic conditions, on physical and cultural heritage, on the current use of lands and resources for traditional purposes by aboriginal persons, or on any structure, site or thing that is of historical, archaeological, paleontological or architectural significance, and (c) any change to the project that may be caused by the environment, whether any such change occurs within or outside Canada.

11.2 Regional Impacts

The EIS should discuss whether existing environmental conditions, including other uranium developments in the area, could influence the project. The discussion should address whether

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the project-specific effects of the 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 Act3, and Cumulative Effects Assessment Practitioners Guide4 should also be consulted regarding the scope of cumulative impacts to be evaluated in the EIS.

11.3 Project-Specific Impacts

The EIS should document and evaluate the significance of positive and negative project-related impacts of the project on the environment and whether the predicted impacts would alter the levels of environmental impacts previously assessed for the Cigar Lake development. To provide context the EIS should discuss whether:

• previous modeling predictions for the Cigar Lake site have been verified by current operational monitoring data, and explain those modeling predictions that have been disproved or not been verified by current operational monitoring to date; and

• historic exploration and industrial development activities have influenced the current status of the environment, fisheries, wildlife or resource use at the proposed site of the project.

Impact predictions should be categorized according to defined criteria, and should be as specific and quantitative as possible. Source terms for potential surface water, ground water and atmospheric impacts, together with contaminant transport and plume dispersion modeling results should be provided. A key element in the project is the potential for contamination of the Aline Creek/Seru Bay/Waterbury Lake aquatic ecosystem. The EIS should describe current assessments of waste loadings and dispersion in this aquatic receiving system and demonstrate that the project would not lead to contaminants and loadings in aquatic receiving system in excess of the system’s assimilative capacity. Related information should include:

• current physical and chemical status (including radium, copper, molybdenum), and sediment quality, of the areas currently receiving discharges of treated mine water effluent (e.g., Aline Creek watershed and Seru Bay/Waterbury Lake) and any observed trends;

• potential contaminant loadings to Seru Bay and Waterbury Lake and potential effects on sediment quality;

• full details of the derived limit approach used for the assessment of the assimilative 3 Canadian Environmental Assessment Agency. 1999. Operational Policy Statement OPS-EPO/3-1999 Addressing Cumulative Environmental Effects Under the Canadian Environmental Assessment Act (http://www.ceaa-acee.gc.ca/013/0001/0008/guide_e.htm#cumulative) 4 Canadian Environmental Assessment Agency. 1999. Cumulative Effects Assessment Practitioners Guide (http://www.ceaa-acee.gc.ca/013/0001/0004/index_e.htm)

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http://www.ceaa-acee.gc.ca/013/0001/0008/guide_e.htm#cumulative

http://www.ceaa-acee.gc.ca/013/0001/0004/index_e.htm


capacity of Seru Bay/Waterbury Lake to receive contaminants of potential concern; and

• modeling used to estimate future mass loading, transport, and fate of contaminants of potential concern in treated mine water effluents discharged into Seru Bay and potential impacts on Seru Bay and Waterbury Lake.

The EIS should identify where contaminant levels would, and would not, meet Saskatchewan Surface Water Quality Objectives and Canadian Water Quality Guidelines in the aquatic receiving system and provide an evaluation of any environmental impacts. The EIS should provide the locations (e.g., UTMs) where objectives/guidelines are not met to provide an indication of the potential migration of effects. Potential impacts on Seru Bay/Waterbury Lake are critical issues for environmental protection. The EIS should address:

• anticipated short and long term aquatic environmental effects of continued loading of chemical parameters on receiving waters (water quality and sediment quality change) and predicted mixing effect zone;

• potential for variation in the physical and chemical parameters (e.g., contaminants of potential concern, such as molybdenum, radium and copper), conductivity, temperature, of the treated mine in-flow waters released into Seru Bay and implications for the receiving aquatic environment, including seasonal effects;

• implications of any changes to operational levels/balances of water treatment reagents used and concentrations of reagents (or their breakdown products) in effluents;

• potential extent of the treated mine water inflow effluent discharge plume in Seru Bay and Waterbury Lake;

• potential impacts of water quality changes in Seru Bay/Waterbury Lake to benthic invertebrates, fish, wildlife and plants based on contaminant transport modeling results;

• monitoring programs for potentially affected biota; • use of abiotic and biotic monitoring programs in evaluating the aquatic and terrestrial

environmental effects of this project; and • 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.

The EIS should address the assessment of potential terrestrial and aquatic impacts of pipeline construction, with particular attention to the in-lake construction phase, and discuss potential impacts to woodland caribou habitat and/or behaviour as a result of the permanent linear disturbance. The potential implications of in-lake site selection criteria, timing of construction,

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construction methods and proposed technology to diffuse the release of treated mine inflow waters into Seru Bay should be discussed in detail. Potential impacts to any surface waters, stream/lake banks and riparian areas should be identified and appropriate mitigative measures proposed. Setbacks for development activities adjacent to any fish-bearing and non-fish-bearing waters would be required. The EIS should discuss any potential impacts to local/regional groundwater regimes as a consequence of routine and non-routine mine water inflows and the anticipated quantity, quality and flow rates of groundwater potentially affected. This discussion should include an evaluation of the potential for any impacts to adjacent surface waters (e.g., on lake levels and water quality). The EIS should discuss whether the project would affect the current status of Cigar Lake with respect to contribution to greenhouse gases and other climate change parameters. The potential impacts from all contaminant sources should be combined to provide a cumulative impact assessment for the Cigar Lake site and an assessment of post-decommissioning contaminant loadings to the environment. These assessments should be discussed in the context of criteria for the design of operational monitoring programs and decommissioning, reclamation and abandonment planning. The EIS should assess the potential effects of any 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 and heavy metals), into food chains and the terrestrial or aquatic environment should be described.

11.4 Mitigation and Contingency Planning

The EIS should discuss existing adaptive management, mitigation measures, and current contingency planning at Cigar Lake and any changes necessary to incorporate technically and economically feasible measures necessary to mitigate the potential terrestrial and aquatic impacts associated with the pipeline construction and release of the treated mine water inflow effluent into Seru Bay. A hazard analysis or other risk-based approach should be used to identify situations where adaptive management or mitigative measures may be needed (e.g., where environmental effects pose a risk that is higher than expected). If engineering or administrative control solutions are not technically and economically feasible, then contingency plans should be developed. Also, future monitoring and risk assessment modeling may identify the need for changes or additions to mitigation planning (e.g., changes to effluent treatment procedures, to manage unforeseen issues associated with toxicities of contaminants of potential concern, such as radium, molybdenum, copper or selenium). Although the detailed mitigation and contingency plans would be designed in consultation with regulatory agencies during licensing and would be subject to periodic review during operations, the EIS should document mitigation and contingency plans which would be

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

11.5 Effects of the Environment on the Project

The assessment must also take into account how the environment could adversely affect the project; for example from severe weather. The assessment must take into account any potential effects of climate change on the project, including an assessment of whether the project is sensitive to changes in climatic conditions during its lifespan (e.g., impact on multi-year water balance calculations such as potential alterations to lake levels and the placement of the diffuser). Guidance can be found on the CEAA website5. 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.

12.0 MONITORING

The EIS should identify the need for, and requirements of, any follow-up assessment or monitoring programs for the proposed project and any changes to the current baseline and operational monitoring programs at Cigar Lake. Although the detailed monitoring programs would be designed in consultation with regulatory agencies during licensing and would be subject to periodic review during operations, the EIS should provide a description of proposed programs (e.g., parameters, locations, sampling frequency, methodology). Taking into consideration recently improved techniques, the monitoring programs should be consistent with baseline data sampling methodology and be compatible with the existing regional environmental database. The EIS should address:

• monitoring programs for any potential environmental impacts, including potential contaminant loadings to plant and animal species, that are significant in the food web and that are considered relevant VECs;

• programs to monitor sediment quality in Seru Bay and areas of Waterbury Lake potentially affected by the project;

• monitoring programs to confirm ground water and surface water quality in the vicinity of Cigar Lake over the life of the project, including post-decommissioning; and

• commitments for operational response procedures to be followed should monitoring identify environmental changes or unforeseen/unacceptable impacts.

5 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

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


Monitoring not only should ensure compliance with regulatory requirements but also should 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. Any monitoring 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 and of the CNSC license. Development of monitoring programs should be made with reference to MOE’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". The need for, and requirements of, a federal ‘follow-up program’ in respect of the project is required. The purpose of the follow-up program is to assist in determining if the environmental and cumulative effects of the project are as predicted and to confirm whether the mitigation measures are effective.

13.0 DECOMMISSIONING, RECLAMATION AND ABANDONMENT

Although the detailed plans for decommissioning, reclamation, abandonment and financial assurance assessment would be developed in consultation with regulatory agencies during licensing, and would be subject to periodic review during operations, the EIS should provide descriptions of the key elements of these plans.

13.1 Conceptual Decommissioning Plan

The EIS should briefly describe the existing conceptual decommissioning plans for Cigar Lake. Reference to CNSC ‘s Regulatory Guide G-219 is recommended6. The EIS should focus on any modifications which may occur as a consequence of the proposed project and any changes from previous EIS commitments relating to decommissioning, including:

• decommissioning objectives; • alternative procedures for decommissioning site facilities; • preferred procedures for decommissioning; • decommissioning, reclamation and abandonment of all related works and surface

disturbance; • identification of acceptable post-operational land use options for the project site; • environmental mitigation and reclamation measures (e.g., contouring, waste

stabilization and re-vegetation); • post-operational landforms and drainage systems; and • proposed contingency measures.

6 CNSC Regulatory Guide G-219. June 1, 2000. Decommissioning Planning for Licensed Activities.

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The plan should address potential post-decommissioning contaminant loadings and impacts to local surface drainage and groundwater systems. The conceptual plan should reflect project impact assessment, mitigation and monitoring experience. The plan should identify, to the extent possible:

• environmental impacts which can be mitigated by post-decommissioning procedures; • impacts which cannot be mitigated - these impacts constituting irretrievable

environmental losses accruing to the province and to future generations; and • any potential opportunities for environmental enhancement.

Procedures to ensure that resources are available to implement the plan on mine closure, or at an unscheduled time, should be discussed.

13.2 Reclamation

Reclamation planning concepts that should be included in the EIS are described in MOE’s draft document EPB 381, “Guidelines for Northern Mine Decommissioning and Reclamation, Version 6, November 30, 2008”. These guidelines include criteria for cleanup of soils contaminated by chemical or radioactive materials. All disturbed sites should be reclaimed as soon as possible after disturbance and operating procedures that may minimize post-operational reclamation and abandonment requirements should be identified. Supporting documentation for proposed reclamation programs should be included in the EIS.

13.3 Financial Assurance

If the project is approved, a condition of licensing would require that the decommissioning cost estimates for Cigar Lake currently approved by the provincial and federal governments would need to be reviewed to determine if any additional liabilities would be incurred by the proposed project. Any significant new cost liabilities should be identified in the EIS together with a discussion of the cost-estimating approach. Reference to CNSC’s Regulatory Guide G-206 is recommended7.

13.4 Abandonment and Institutional Control

The EIS should include proposed criteria for abandoning the project and associated infrastructure and commitments for the monitoring of decommissioning success prior to final abandonment. Provisions for the long-term institutional control should be discussed, including, but not being limited to:

7 CNSC Regulatory Guide G-206. June 1, 2000. Financial Guarantees for the Decommissioning of Licensed Activities.

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• record keeping or archiving that fully describes past operations, decommissioning plans and assessments, final configurations, and release verification;

• post-abandonment site monitoring and verification; • 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 project 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.

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