Panel Report

The primary focus of these reviews has been the environment of northern Saskatchewan and its preservation for future generations.

The mines are located in a part of Canada that is largely undeveloped and free of the negative impacts that industrial development often brings to a geographical area. Such an environment is often more vulnerable and more valuable than others that have already been impacted by industry. Preservation of a pristine environment is preferable in every way to restoration of an environment that has been allowed to deteriorate.

The importance of the environment to the residents of northern Saskatchewan was clearly drawn to our attention very early in the review by Maureen Ahenakew:

The earth gives us our sustenance. Our survival, our lives depend on the purity and the cleanliness of the earth. In my mind it's so clear, and there is no confusion, or, I guess, it can't be said any more simpler than to say that we are risking the lives of everyone by continuing with any kind of mining or any kind of destruction of the earth. I see uranium mining as being just that--destruction of the earth. In a common sense thinking, you think of it as destruction of the earth means immediate economics. Economics are not going to do us any good. Money is not going to do us any good, if there is no life. It has no value. We all need water, we all need food and we all need to eat, we all need to drink. We all need to breathe air in order to survive--all of us. It does not matter what colour we are or which part of the world we live in, we all need all of those things to survive. If they are poisoned, then we are poisoned. We see it now. [Maureen Ahenakew, Transcript of Public Hearings on the McArthur River Underground Exploration Program , Saskatoon, Saskatchewan, December 4-5, 1992, p. 71.]

Others, such as John James Mercredi, were less convinced of mining's negative impacts on the northern environment:

The issue that we're talking about here, we're talking about mining activity in northern Saskatchewan. And some people are instigating, I guess they were saying, that mining destroys the environment. I would like to see some proof of that because like I said, worked in the mining industry myself. And when it comes to a disruption in the land and disruption in the environment as well as wildlife, I'd like to see some concrete evidence. I need to see more of that. I need to hear that from the people here as well too. So just a bit of a challenge, I guess you can say, with regards to changes in the environment that you have seen because of this mining activity. You know, I have to hear from people who have witnessed it. [John James Mercredi, Transcript of Public Hearings on the McClean Lake Project, Midwest Joint Venture Ltd., and Dominique-Janine Extension at Cluff Lake , Black Lake, Saskatchewan, April 13, 1993, pp. 103-104.]

Still others supported mining on the understanding that it would be done in cooperation with northern people and that northern residents would be guaranteed a majority share of the employment opportunities. Facing the proponents one evening in Black Lake, the elder, Louis Chicken, had this to say:

So when I talk about our people today, we're very poor. I know that. And I'm asking for opportunities for my future generations. And when we talk about these types of things, and as I've always done, I will always continue to do that I guess. You're saying that you're creating opportunities for us today. And we need guarantees. Because in the past I don't think we've had opportunities like that where we were given options, I guess. And right now I think that the direction that things are going with opportunities that you're talking about creating, is the way to go.

Because at least we will be given chances, I guess you can say, to better our lives if we could be party to those jobs that you are talking about creating. So I think helping each other and dealing with each other, face to face, is the way to go. Like I said already, I don't speak for myself. And I speak for a lot of the young people who are watching here today. And when elders speak, they try and provide the best information they can for people around them.

And like I've always done in my past practices as a political leader for my people, I try and deal with these issues head on. And deal with them person to person to resolve it. And if you could reach an agreement where these jobs that you're promising would be protected, would be the way to go. Thank you. [Senator Louis Chicken, Transcript of Public Hearings on the McClean Lake Project, Midwest Joint Venture Ltd., Dominique-Janine Extension at Cluff Lake , Black Lake, Saskatchewan, April 13, 1993, p. 145.]

After listening carefully, reading widely, and debating at length, we have concluded that the best course is to recommend that the mines be allowed to proceed under conditions that would minimize environmental damage and maximize northern benefits.

We are aware that the environment can recover from most of the immediate impacts of mining. Over time, the terrestrial disturbances that occur when the mine sites and roads are constructed will become revegetated and habitable by birds, animals and people. Over time, the lakes and streams will be cleansed of contaminants that are released in the mine effluent, provided that regulatory limits are observed. Over time, atmospheric pollutants will be dispersed until they are negligible compared to background levels. Such environmental impacts, we concluded, could be tolerated in the interest of providing northern people with economic opportunities.

There are, however, other long-lasting impacts associated with the disposal of waste rock and tailings with which nature may not be able to cope.

We are very concerned about the potential continuing environmental damage that could result from acid mine rock drainage. There are no natural processes, of which we are aware, that would serve to mitigate acid mine rock drainage in northern Saskatchewan. If allowed to occur, it would destroy habitat and impact negatively on the environment for as long as it is possible to foresee.

Tailings management facilities have an even greater potential for contamination of the ground water over the long term. If the disposal pits currently being considered fail to function as expected, and if mitigative measures are not at hand, extensive pollution could occur.

It is these two long-term threats to the environment, and their need for monitoring, that are the subjects of the remainder of this section. It is essential that future generations not be left with problems that cost more to mitigate than the current generation derives in benefits.

2.1 Disposal of Mine Waste Rock

It is usually necessary to remove large volumes of overburden to gain access to an ore-bearing deposit. This non-ore-bearing rock, which miners refer to as waste, may be considered to be clean if it contains no soluble heavy metals or minerals that can be oxidized by atmospheric oxygen. Some clean waste can be used as construction aggregate, thereby providing a measure of value-added benefit from mine waste materials. Unfortunately, not all clean waste rock materials can be disposed of in such a beneficial fashion; some must be permanently deposited on the surface of the earth. Such waste piles, if properly contoured and vegetated, cause an altered landscape, but little or no environmental damage. A good example of a well-contoured and revegetated waste pile may be observed at the Cluff Lake site where hydroseeding has been used to accelerate revege-tation.

Precipitation will flush readily soluble contaminants from waste piles containing mineralized wastes (sometimes called special wastes). In Saskatchewan uranium mines, the principal contaminants are uranium-derived radionuclides and heavy metals (particularly arsenic and nickel, and to a lesser extent copper, zinc, cadmium, molybdenum and iron). If the waste also contains sulphide minerals, exposure to oxygen and water results in the formation of acids which accelerate the release of heavy metals and radionuclides from the waste pile. [L.M. Broughton, R.W. Chambers and A. MacG. Robertson, Mine Rock Guidelines, Design and Control of Drainage Water Quality , Saskatchewan Environment and Public Safety, April, 1992, Chapter 3.] The impact of this acid mine rock drainage is to pollute the drainage area in the immediate vicinity of the waste pile and downstream in decreasing concentrations. For this reason, mineral-containing wastes cannot be placed in surface waste piles; they must, instead, be disposed of in a way that eliminates or greatly reduces exposure to atmospheric oxygen. Research has indicated that the two best ways of doing this are to return the waste underground where reducing conditions prevail or to store it under a cover of water. [Ibid, Chapter 6.]

Current research into the understanding and mitigation of the release of contaminants from waste rock is well advanced. Uranium mines in Saskatchewan have participated in the Mine Environment Neutralization Drainage (MEND) program by providing sponsorship of workshops on the development of water cover technologies. Such participation in the development of new technologies for mitigating impacts associated with waste rock disposal indicates the high level of concern exhibited by the various proponents. They are also to be commended for their initiatives to replace maximum quantities of mine waste rock either underground or into open pit excavations.

The methods proposed for handling waste rock at the Midwest and Cigar Lake projects provide examples of the major difficulties that may be encountered. For the Midwest Project, Cogema proposed that a quantity of inert waste rock, approximating 110,000 tonnes, be abandoned at a site adjacent to the underground mine, on the west shore of Mink Arm. [The Midwest Project Environmental Impact Statement, Main Document , Cogema Resources Inc., August, 1995, pp. 2-47.] This waste pile would represent a new topographical feature along Mink Arm that might cause some change in drainage patterns. Such an impact would be acceptable if it were not for the possibility that the imperfect separation of clean and special waste might result in acid mine rock drainage into Mink Arm. In general, there is a concern about the proponents' ability to separate clean and potentially acid-generating waste rock.

Classification of waste as clean or special is based on the results of advance drilling and subsequent laboratory testing of the samples from that drilling. [The McArthur River Project Environmental Impact Statement, Addendum , Cameco Corporation, June, 1996, p. 2.1.13.] Although the mining companies express confidence in this procedure, the fact that there is no way to assess the acid-generating potential of the waste rock in each truckload emerging from the mine leaves concern in the minds of some members of the public. In our opinion, there is a need to find more precise methods for distinguishing between potential acid-generating waste and non-acid-generating waste as excavation proceeds. Research directed toward the development of such methods could prove to be a good investment.

At Cigar Lake, the proponents face a different problem. There, very little of the waste rock is clean and a way must be found to safely dispose of 2.6 million tonnes (1.35 million cubic metres) [The Cigar Lake Project Environmental Impact Statement, Main Document , Cigar Lake Mining Corporation, July, 1995, p. 3-99 and Table 3.6.31.] of potentially acid-generating rock. To accomplish this, the proponent proposed underwater storage, first at Bizarre Lake and, later, at Lake 497 when it was discovered that Bizarre Lake provided valuable fish habitat. However, a representative from the Department of Fisheries and Oceans cautioned that, "Granting approval for this disposal of potentially acid generating waste rock into a lake inhabited by fishes would be precedent-setting for northern Saskatchewan," [B. Fallis, Transcript of Public Hearings for the McArthur River and Cigar Lake Projects , Saskatoon, Saskatchewan, September 18, 1996, p. 148.] and Environment Canada recommended that consideration should be given to the possibility of disposing of the mine rock wastes in one of the mined-out pits at the nearby McClean Lake site. [Environment Canada, Technical Position on the Cigar Lake Uranium Project , September, 1996, p. 11.]

Both solutions, lake and pit disposal, contain future uncertainties that could result in environmental damage. It appears that waste rock disposal in Lake 497 would not cause an unacceptable loss of fish habitat; however, it is possible that future conditions, as yet unrecognized, could cause the water level to drop, exposing the wastes to atmospheric oxygen. On the other hand, the pits at McClean Lake have yet to be completely excavated and the hydrogeology there may make them unsuitable for waste rock deposition. Furthermore, it is expected that the Sue pits may not be fully excavated by the time Cigar Lake starts production, thereby requiring the storage of waste rock on surface in contact with atmospheric oxygen for several years before deposition could begin. By the time that deposition could begin, the acid-generating processes would be well established in the stockpile.

As can be seen from these examples, none of the choices for waste rock disposal can be made with complete assurance that all future impacts will be acceptable. In principle, however, we do not favour the use of lakes as waste depositories if other acceptable options are available. Philosophically, it does not seem that the use of a lake for waste disposal is compatible with environmental preservation, especially if there are mined-out pits nearby. We are in general agreement with the stated position of Environment Canada:

Subsurface disposal of all tailings, special waste and waste rock would appear to mitigate all potential long-term environmental problems at surface waste piles and flooded pits. This is Environment Canada's preferred option for the disposal of all solid wastes from new Saskatchewan mines. [Environment Canada, Technical Evaluation of the Environmental Impact Statement, Midwest Uranium Project , August, 1995, p. 20.]

Ideally, pits that are used for waste depositories should be completely filled and capped with several metres of clean waste and till to avoid the formation of water ponds in the top of the pit. Over time, contaminants may diffuse upward from the wastes into such ponds, presenting a health hazard to people or animals who drink the water.

2.2 Milling and Tailings Management Facilities

2.2.1 The Milling Process

The milling of the ore derived from uranium mines is a well understood and widely used operation. Although the chemistry of the milling process is somewhat complex, [The Cigar Lake Project Environmental Impact Statement, Response to Request for Additional Information on the Cigar Lake Project, Cigar Lake Mining Corporation, March, 1996, p. 4-1.] the essential steps are:

• crushing of the mine rock to expose the uranium minerals to the action of chemical reagents;
• oxidation of all uranium present to yield dioxouranium (VI), UO₂⁺⁺;
• calcination of the precipitate to yield yellow cake, U₃O₈;
• neutralization of the tailings; and
• deposition of tailings in the tailings management facility.

For certain ores, other metals such as nickel, cobalt or molybdenum are also extracted in separate operations.

Although these processes have been successfully used for many years, it is apparent that improvements are still possible. For example, when the Province of Saskatchewan required Cogema to conduct research into ways to reduce process chemicals as part of the approval of the McClean Lake mill, [The Government's Position on Proposed Uranium Mining Developments in Northern Saskatchewan, Province of Saskatchewan, December, 1993.] it was found possible to make changes that resulted in a 28-per cent reduction in the volume of tailings discharged. [The Midwest Project Environmental Impact Statement, Main Document, Cogema Resources Inc., August, 1995, p. 3-4.] There seems little doubt that a sustained program of research would result in further efficiencies with respect to the amount of chemicals used and the toxicity of the tailings produced. Considering the vast reserves of uranium already known in northern Saskatchewan and the potential for the discovery of additional deposits, there is every indication that uranium mining will continue for several decades and that an applied research program would be a good investment. We are, therefore, recommending that the province, in cooperation with the industry, take measures to promote a continuing scientific search for ways to improve the milling process.

2.2.2 Liquid Effluent

Milling produces contaminated water that must be treated before release into the environment. Other sources of liquid effluent that also require treatment include mine water and pore water expressed from the tailings. The treatment process is designed primarily to decrease the concentration of radio-nuclides and toxic heavy metals in the effluent by addition of chemical reagents that form precipitates with metal ions. For example, radium is removed by addition of barium chloride to produce a coprecipitate of barium sulphate and radium sulphate. This process decreases the concentrations of radionuclides such as radium and other heavy metals, but results in an increase in the concentration of soluble salts (primarily chlorides and sulphates) in solution.

Water treatment, therefore, involves an environmental trade-off, whereby the mitigation of one problem (containment of heavy metals and radionuclides) creates or exacerbates another problem (increased salinity). The environmental impact of increased salinity is acceptable for two reasons: it is less harmful than elevated concentrations of radionuclides and heavy metals; and, the salinity change in the receiving waters is not permanent. After decommissioning, when water treatment stops, the salt concentration will drop to background levels and any organisms that have been eliminated because of the change in salinity can reinvade and become re-established.

Precipitation processes reduce the concentration of radionuclides and heavy metals but do not completely remove them from the effluent. Therefore, the total environmental loading of these contaminants can still be considerable if sufficiently large volumes of effluent are released. Even though the concentrations of radionuclides and metals are very low, the large volume of effluent means that surprisingly large amounts of these elements are released. For example, the Department of Fisheries and Oceans has calculated that 103,230 kg of uranium would be released in treated effluent discharged from the McClean Lake project. [Position and Technical Review of the Response to the Uranium Mines Review Panel Request for Additional Information concerning the Complementary McClean Lake and Midwest Projects, McClean Lake Project, Department of Fisheries and Oceans, Central and Arctic Region, Submission to Panel, March, 1993.]

The spread of radionuclides and metals can be limited if they are absorbed by the sediments and suspended particulate matter. Contaminants will spread less if the effluent is released into a bog or lake where the water is in contact with organic sediments for a long period, than if released into a river or lake with a larger turnover rate.

The two problems posed by liquid effluent are antagonistic; a decrease in the one (salinity) leads to an increase in the other (total environmental loading of radionuclides and heavy metals). Moveover, they are resolved in incompatible ways. In the first case, the effluent should be diluted as rapidly as possible to flush the salts from the system; in the second, the aim is to confine the effluent for as long as possible to allow time for contaminants to be adsorbed from solution.

One procedure that is compatible with both problems is the reduction of the volume of effluent by decreasing mine-water inflow and by recycling water in the milling process as much as possible. A second compatible resolution is the removal of radionuclides and metals from the contaminated water by other processes, such as adsorption onto organic particles or ion exchange columns. Both of these possibilities merit further research.

We wish to reiterate three recommendations that we have previously made with respect to the release of liquid effluent. First, a research program should be established to search for innovative ways to reduce the volume of effluent and the quantity of chemicals required to treat contaminated water. The objectives should be a zero-effluent mill and minimal liquid effluent from other mining operations.

Second, site-specific surface water quality objectives, appropriate for the Athabasca region, rather than for Saskatchewan as a whole, should be developed. The present Saskatchewan Surface Water Quality Objectives (SSWQO), applicable for southern Saskatchewan where there is often a high concentration of total dissolved solids (TDS) in the water, are not always appropriate for the Athabasca region. In addition, the new objectives should include a uranium water quality guideline for aquatic biota, and guidelines for any other significant ions or elements which are presently excluded.

Third, the total environmental loading should be specified for all contaminants. Each mine should be required to develop a material-balance for all contaminants released in its effluent. Through their monitoring programs, the individual mines should be able to account for the spread of their contaminants in the watershed, and SERM should compile a cumulative record based on the individual reports. The spread of contaminants on a regional scale would be monitored by the CEMWG (see Section 2.4). It is essential that an improved understanding of the spread of these contaminants throughout the environment be obtained.

2.2.3 Tailings

The composition of tailings produced from the milling of uranium ore will be determined by the process chemicals added and the mineralogy of the ore. For example, if the ore being milled contains a high concentration of arsenic or some other toxic metal, the tailings will also contain high concentrations of those same metals. Moreover, the metals in the tailings will be in chemical forms that are more soluble and consequently more mobile than they were in the original ore body. This is so because constituents of undisturbed ore will have attained an equilibrium in which the metals have combined with other elements to form insoluble minerals; however, the milling process, which involves grinding of the ore and oxidation of the exposed minerals, produces metallic elements in more soluble forms.

Many of the heavy metals displaced from their equilibrium states in this way are toxic and some are radioactive. For this reason, it is necessary to ensure that they are not released to the environment where they could cause widespread contamination of the surface and/or ground water. Because it will take a very long time for them to return to an equilibrium state in which they are insoluble and consequently immobile, it is necessary to provide containment measures that will last indefinitely.

The need to provide containment in perpetuity suggests that the use of engineered structures is not likely to be satisfactory. Attempts to contain tailings behind an engineered dam, for example, might result in environmental problems for succeeding generations if the dam fails at some distant time. Since there are very few engineered structures that have endured for the length of time required for tailings containment, it appears intuitively more acceptable to use natural barriers that would undergo change only on a geologic time scale. It is primarily for this reason that all of the most recently planned tailings management facilities (Rabbit Lake, Key Lake and McClean Lake) have used mined-out pits where the physical barriers are rock formations that have been in place for eons. [Opportunity North, Northern Mines Monitoring Secretariat Supplement, Vol. 4, No. 3, 1997.]

Subsurface placement of the tailings with an adequate cover eliminates the possibility of contact with the biota on the surface of the earth in the short term. However, possible long-term contamination by migration of toxic and/or radioactive metals through the ground water is of greater concern. The operators of all of the existing or proposed tailings disposal pits have provided modelling studies that indicate the tailings, in most cases, will consolidate to form an impervious plug and that migration of contaminants will be slow. We sincerely hope that the modelling exercises prove to be fairly accurate; however, experience has taught that it is wise not to confuse modelling studies with reality and we have, therefore, recommended that the performance of these facilities be carefully monitored to ensure that consolidation is occurring and that contaminant migration is below acceptable limits. Furthermore, realistic mitigation measures for any likely problem with the system should be identified prior to the start of tailings deposition.

On the basis of our current understanding of tailings management facilities, we have concluded that sub-surface deposition is preferred to the use of above-ground facilities and that, wherever it is feasible, tailings currently stored aboveground should be placed below the surface of the ground. We are also in agreement with the current practice of using one mill and one tailings disposal facility for several mines. The complexity of long-term monitoring and maintenance will be directly related to the number of tailings disposal sites in existence. Great care should be taken when a site for subsurface disposal is selected; it is usually better to choose a site after the pit has been completely mined out and the geology and hydrogeology of the surrounding formations have been thoroughly studied.

Our most urgent recommendation with respect to tailings management facilities is that they be carefully monitored from the very beginning and that a monitoring regime which will endure indefinitely be established for all of the tailings management sites in northern Saskatchewan. Since in-pit tailings technology cannot be considered to be fully proven until it has been shown that the tailings are consolidating and that the rate of migration of contaminants is low, it will not be possible to satisfactorily evaluate the performance of these facilities for several decades. Until that time, the owners should be responsible for the cost of any required mitigative measures. Beyond that time, the Province should undertake to provide continuing monitoring and mitigation, if necessary.

For this reason, the panel has recommended the establishment of a contingency fund to provide for the on-going costs of long-term monitoring (and mitigation, should it be required) after the responsibility for the sites have been returned to the Province. [D.G. Lee, J.F. Archibald and R. Neal, McArthur River Uranium Mine Project, Supply and Services Canada, February, 1997, p. 48.] An industry-wide fund would provide better overall fiscal protection to future generations and cost less, in total, than individual funds for each site. There could also be a single authority to manage the fund and oversee the maintenance, monitoring and mitigation activities at all decommissioned uranium mine and mill sites. It is anticipated that the authority would be located in northern Saskatchewan and employ primarily residents of Saskatchewan's north.

2.3 Decommissioning

Saskatchewan has been a major uranium producer since 1953. The first twenty years of mining production occurred on the north shore of Lake Athabasca in the area around Uranium City; three mills -- Gunnar, Lorado, and Eldorado -- operated in that region. During the mid-1970s, uranium mining moved further south into the Athabasca Basin to the sites which are still operating at Cluff, Key and Rabbit Lakes. More recently, new mines have been approved at McArthur River and McClean Lake.

To date, no uranium mining operation in northern Saskatchewan has been completely decommissioned. Although initial work was done at the Eldorado site in the early 1980s, decommissioning efforts continue to this day in an attempt to mitigate concerns with the tailings management area. The length of time required to complete the Eldorado decommissioning is understandable in terms of its history; the mine started operations in the mid-1950s, when there was little concern for, or knowledge about, the design of tailings management areas that provided environmental protection or long-term containment.

The other two mining and milling operations on the north shore of Lake Athabasca, Gunnar and Lorado, were privately owned and no site decommissioning or reclamation took place when the owners ceased operations in the mid-1960s. As a result, each site continues to discharge varying levels of contaminants to the environment. In addition, all of the Gunnar site buildings were left intact and have deteriorated to the extent that they are also a safety hazard.

A question frequently raised in public hearings, particularly by northerners, regarded the ability or willingness of operators to successfully decommission existing mines and any new mines that might receive approval. To date, neither industry nor government has demonstrated a strong commitment to decommissioning abandoned uranium mining sites.

Over the past four years, the Governments of Canada and Saskatchewan have approved an increase in uranium production from which both will accrue substantial benefits. It would, therefore, be appropriate for the federal and provincial governments to address the environmental legacy of uranium mining by working cooperatively to ensure the full decommissioning of all abandoned uranium mine sites and tailings disposal areas in Saskatchewan.

2.3.1 Financial Guarantees

During hearings held in 1993, the public made it clear that decommissioning costs should be the financial responsibility of the mining companies and not of the government; i.e. the taxpayers. The public's strong conviction on this issue stems from the way in which mines near Uranium City were abandoned when no longer profitable, with the costs of decommissioning and reclamation left to the public purse.

In our October, 1993 report, we recommended "that a financial guarantee to cover the cost of decommissioning and post-decommissioning costs of a project be secured from the proponent before the project is approved". [D.G. Lee, J.F. Archibald, J. Dantouze, R. Neal, A. Yassi, Dominique-Janine Extension, McClean Lake Project, and Midwest Joint Venture, Supply and Services Canada, October, 1993, p. 15.] In 1996, during hearings on a subsequent proposal, we were informed that, in Saskatchewan, the requirement to provide such a guarantee became law on March 5, 1996, as part of changes to the Mineral Industry Environmental Protection Regulations and that the Atomic Energy Control Board (AECB) had accomplished the same objective by an amendment to the Uranium and Thorium Mining Regulations.

These changes to both federal and provincial regulations pertaining to uranium mining decommissioning provide a measure of protection for the tax-paying public

2.3.2 Uranium Mining Contingency Fund

Throughout the public hearings on all seven proposals, presenters were insistent that, because of the continuing toxicity of many of the contaminants, the mine and tailings sites should be monitored long after operations have ceased. We agree with that concern. We believe that a dedicated and self-sustaining fund would be the best way to finance postdecommissioning monitoring and to cover the cost of any mitigation that might be required.

We first recommended such a fund in the McArthur River report noting that the Deilmann Tailings Management Facility, in particular, would require long-term monitoring and possible mitigation in the future.

In its response to this recommendation, the Government of Saskatchewan stated:

Recognizing its responsibility for long-term management of the site, the Province is investigating options, including a contingency fund as proposed by the Panel, for implementation of monitoring and the funding of possible mitigation should it be required. [The Government's Position on Proposed Uranium Developments in Northern Saskatchewan, McArthur River Project, Government of Saskatchewan, May, 1997, p. 21.]

The recommendation for a contingency fund, reiterated in the Midwest and Cigar Lake reports, is repeated here. It would be more appropriate to establish this fund in response to cumulative concern about decommissioning costs, rather than in response to concern about a single uranium mining project. The government is encouraged to establish the Uranium Mining Contingency Fund as quickly as possible.

2.3.3 Ongoing Research

The mining regulations administered by both the federal and provincial governments require that a site-specific conceptual decommissioning plan be prepared by the proponent. This plan, which includes proposed reclamation activities and associated costs, must be submitted, reviewed and approved prior to the issuance of an approval to operate a mine. The conceptual plans are judged to be acceptable if the sites can be decommissioned using existing technology.

Proponents and regulators must not be complacent with existing technology; research efforts must continue, focusing on advancing decommissioning technology in an effort to minimize the environmental footprint left by mining and milling activities. It is imperative that every effort be made to return disturbed areas to as near to premining conditions as possible and to ensure that the sites are physically and chemically stable over the long term.

2.3.4 Local Involvement

During public hearings, it was also evident that members of the public, particularly northern residents, feel the need for local communities to be consulted on both the conceptual and final decommissioning plans. Since it will be their descendants who will have the decommissioned sites in their backyards, it is important that they be involved not only in developing the plans, but also in implementing the decommissioning, reclamation and postdecommissioning monitoring. The Environmental Quality Committees provide an ideal vehicle through which local people can be consulted on decommissioning issues, activities and monitoring.

2.4 Monitoring and Mitigation

The commitment of the proponents to monitoring the concentration of contaminants in the abiotic components of air, water, soil and sediments is in sharp contrast to their apparent resistance to monitoring biological effects. They accept the appropriateness of monitoring the release of contaminants and their concentrations in certain organisms such as fish; they do not acknowledge a need for concern about the effects of these contaminants on the biota in the areas surrounding the mines. For example, in its response to the McArthur River report, the proponent argued against doing biological effects monitoring because Cameco's risk assessment had concluded that there would be little effect on organisms. [Cameco Corporation, McArthur River Project, Response to the Report of the Joint Federal-Provincial Panel, April, 1997, p. 19.] Cameco's position is untenable; the limitations of an impact assessment approach relying only on risk assessment were directly addressed in the panel's report. [D.G. Lee, J.F. Archibald and R.Neal, McArthur River Uranium Mine Project, Supply and Services Canada, February, 1997, p. 36.] Consider an analogous situation, the analysis of radiation risks to workers in the mine and mill. Cameco has concluded that the health risk to workers is very small, but it does not advocate that, as a consequence, there is no need to monitor worker health.

We have recommended the expansion of biological effects monitoring to include, at all mine sites, all of the Valued Ecosystem Components that are monitored for cumulative effects at more distant sites. In addition, we recommend that the technical group that advises on monitoring protocols be broadened to include appropriate expertise from universities and from government institutes. This technical group should hold regular workshops, open to the public and to the Environmental Quality Committees, to review and advise on biological effects monitoring for uranium mines. These recommendations have been endorsed by many northern residents, including representatives of the Environmental Quality Committees.

Throughout the public hearing process, one of the overwhelming public concerns has been that uranium mining might pollute the water and biota around the mine sites irreversibly. People are not reassured by risk analyses and modelling predicting that their fears are groundless; they demand that the mining companies prove that contaminants are being successfully contained and not damaging the surrounding ecosystems. This can only be achieved with monitoring programs that are carefully designed and implemented with the involvement of local people.

In response to a 1993 panel recommendation, Saskatchewan Environment and Resource Management and the Atomic Energy Control Board developed a cumulative effects monitoring program in 1994 to examine the regional impacts of uranium mining on the environment. We are encouraged by this initiative and note their establishment of a Cumulative Effects Monitoring Working Group (CEMWG), including a wide range of expert opinion, and subsequent involvement of local residents in helping to sample some of the biota. We would encourage further attempts to give northerners a sense of partnership in the monitoring program and its results.

In addition, we recommend that detailed sediment cores be collected at certain key sites (e.g. at the exits from Wollaston Lake to the Fond du Lac and Cochrane river systems) to provide a history of the flux of contaminants in the region. Such sampling would provide an accurate assessment of the regional spread, if any, of contaminants from the mines.

We also recommend perpetual monitoring for tailings disposal facilities (Section 2.2.3) and for waste rock with acid-generating potential.

The panel's choice of the word, perpetual, was debated during public hearings; the panel's intent requires clarification. Two factors must be recognized when determining the length of time required here for monitoring. First, the containment of contaminants will depend on the structural integrity of engineered solutions being maintained for tens of thousands of years, much longer than all of recorded human history. Where such wastes are disposed of in mined-out pits, one is more confident that the natural rock barrier will change only on a geological time scale. In the case of aboveground tailings facilities, the containment of contaminants will, however, depend on the structural integrity of containment dams, rock or earth covers and diversion dikes. The placement of acid-generating waste rock in lakes relies on the enduring existence of a water cover of sufficient depth to prevent oxidation. Both approaches are susceptible to possible future failures. The engineered structures will degrade slowly through time and changes in weather patterns, as yet unknown, might result in the lowering of the water level of a lake at some distant date.

Secondly, the movement of contaminants might be exceedingly slow even if there is a failure of containment. The movement of contaminants in the groundwater could be of the order of a few centimetres to a few metres per century, depending on the porosity of the rock or glacial till. Consequently, it might take many centuries for contaminants to reach problematic levels in surrounding areas.

Because of these factors, it would be wise to monitor such sites for at least a few centuries in order to confirm model predictions; therefore, in describing monitoring as being required in perpetuity, the panel intends that the regime continue for an unlimited time.

The precise monitoring regime will be site-specific. The groundwater and/or surface water quality will require monitoring, as will the integrity of any engineered structures. Because most of the changes possible would take place very gradually, the monitoring might be infrequent and at increasingly large intervals, in the order of every 10 to 50 years. Consequently, the interest from a small financial endowment would be sufficient to fund the monitoring program in perpetuity.

As important as the funding of perpetual monitoring is the need to have sufficient funds for the mitigation at source of any problems attributed to a failure of containment. We have recommended the establishment of a Uranium Mining Contingency Fund for this purpose (see Section 2.3.2).

Finally, we recommend that northern residents be involved in all aspects of monitoring. The mining companies which perform most of the on-site monitoring are hiring northerners as technicians. Presumably, as training, education and experience increase, northerners will assume supervisory and management roles in the monitoring programs. The regulatory agencies have attempted to involve northern residents in the collection of some monitoring data, and to involve the Environmental Quality Committees (EQCs) in an advisory role.

We acknowledge and applaud these efforts to involve northerners; however, as indicated in the Cigar Lake report, many northern residents are not satisfied and wish to become full partners in the regulatory process. We recommend that the regulatory agencies adopt hiring objectives for northerners similar to those of the mining industry that they regulate. This should be a long-term initiative; in the short term, much of the involvement of northerners will be though the activities of the EQCs.

We are encouraged by the activities of the EQCs and commend the mining companies and government departments for their commitment to work with, and support, these committees. We are, however, acutely aware of the magnitude of the task facing the EQCs. It is vital that adequate continuing financial support be provided to allow these committees to effectively address the many issues related to uranium mining in northern Saskatchewan.