Panel Report

The major recommendations resulting from a review of the McArthur River Project are summarized in this chapter. The information supporting these recommendations, along with other findings, conclusions and secondary recommendations, is presented in Chapters 5 - 13.

4.1 The McArthur River Mine

The non-entry mining methods proposed for use at the McArthur River mine have been designed to protect workers from unacceptable radiological exposure during the mining of the extremely high-grade ore. The methods are well developed and likely achievable by current industry standards. Possible environmental risks are more than compensated for by potential socio-economic benefits and it is therefore recommended that approval for mining be granted, subject to the following conditions:

• that the “as low as reasonably achievable” (ALARA) principle be rigorously enforced to protect workers from unnecessary radiation exposures. In dealing with very rich, highly radioactive ores there is a temptation to become complacent once it has been demonstrated that exposures are below legislated limits. However, the ALARA principle demands that the proponents and regulators seek ways to reduce exposures to the lowest levels that are reasonably attainable, rather than simply meeting regulated standards. This principle must be attached to approvals for mining of the McArthur River ore and rigorously applied to all stages of this project - development, operation and decommissioning;
• that research continue into methods for reducing effluent volume and contaminant concentrations;
• that improved monitoring of environmental impacts be required at, and downstream from, the release sites, as described in Chapters 6 and 10; and
• that improved methods for distinguishing between barren and mineralized waste rock be required. If satisfactory methods cannot be established, all stockpiles should be placed on liners that will permit the collection and treatment of leachate.

4.2 The Deilmann Tailings Management Facility

It is recommended that cautious approval be given to the proposal to deposit tailings from the milling of the McArthur River ore in the Deilmann Tailings Management Facility (DTMF). In-pit disposal is more acceptable, in principle, than above-ground storage, but caution must be exercised because the facility will eventually contain millions of tonnes of waste that is both toxic and radioactive. If not managed properly, this waste could, in the future, contaminate a large area of northern Saskatchewan. It will never be possible to completely walk away from this or similar uranium tailings disposal facilities. The proponents and governments should recognize from the inception of this project that perpetual monitoring will be required to determine if contaminants are leaking from the facility at unacceptable rates. Mitigative actions would be required if the facility does not perform as well as predicted. It is, therefore, imperative that extensive monitoring protocols and appropriate mitigative procedures be identified before the project is approved. If assurances of monitoring for the foreseeable future, along with any required mitigation, cannot be provided, the project should not be given approval.

The following conditions are attached to this recommendation:

• that rigorous performance requirements be part of the approval;
• that procedures for mitigating any potential malfunctions of the DTMF be identified before deposition of the McArthur River tailings begins;
• that performance monitoring procedures for all stages of the operation of this facility be developed and monitoring initiated before deposition of McArthur River tailings begins. If monitoring identifies that the established performance requirements are not being met, mitigation measures must be implemented; and
• that conceptual plans for monitoring of the decommissioned facility in perpetuity be developed before deposition begins.

4.3 The McArthur River-Key Lake Road

It is recommended that approval be given for the construction of a haul road from McArthur River to Key Lake. During the construction of this road, environmental damage should be minimized by following the power line as closely as possible and by using clean mine waste rock as a primary road-building material.

4.4 Northern Benefits and Local Participation

The McArthur River Project, including the mine, the mill, the DTMF and the road, are on land that has traditionally Recommendations and Conditions 13 been used by local inhabitants for hunting and gathering purposes. The entire project is situated on Crown land; however, the local people have an historical and spiritual attachment to the land it will occupy. Determined efforts must, therefore, be made by the proponent and federal and provincial governments to ensure that they derive the maximum possible benefits from the project. In particular, it is imperative that employment and business opportunities for northern people be increased.

Many decisions related to this project must necessarily be made in the future. It is not possible to know in advance what decisions will be required as the project develops. The regulators, who will represent the people of Canada and Saskatchewan in these future decisions, are competent and capable of carrying out their responsibilities; they should, however, ensure that local people are given an opportunity to participate in all significant future decisions. The regulators and proponent cannot afford to deprive themselves of the advice that northerners can give with respect to these projects. In the body of the report, we have made several suggestions for ways in which the participation of northerners in these future decisions can be encouraged; other approaches will undoubtedly be developed over time. What is needed now, before approval is granted, is a commitment on the part of the proponent, of the governments, and of their agencies to actively encourage local participation.

The Environmental Quality Committees and the Athabasca Working Group provide avenues through which governments and the proponent can consult with representatives from the local communities on a regular basis. However, it is also essential that these consultations be expanded periodically to include entire communities.

The long-term viability of the uranium mining industry is dependent upon an improved acceptance by northerners. Both the proponent and governments are obliged to listen more carefully to the wisdom of the local people and to organize northern developments in ways that bring maximum benefits to northern people.

To assist in the achievement of these objectives, the following minimum conditions should be attached to the approval of this project:

• that adequate financial support be provided by provincial and federal governments for the Environmental Quality Committees;
• that regulatory agencies support the Environmental Quality Committees actively and invite their participation in, and observation of, regulatory activities;
• that agreements reached by the Athabasca Working Group be established as part of a legal document;
• that Cameco be required to report annually on its public involvement programs;
• that an objective of obtaining at least 35% of all required goods and services from northern suppliers be established for the McArthur River project;
• that employment objectives for the participation northerners in the mine and mill work force increased from the present level (about 50%) 1% per year until they reach at least 67%;
• that Cameco be required to report annually on commitments made in the EIS with respect employment and business opportunities northerners; and
• of be by its to for that the government agencies and departments providing services in northern Saskatchewan adopt human resources objectives that would lead to a substantial increase in northern participation on their staffs.

4.5 Monitoring

The effects of mining on the northern environment and on the vitality of northern communities will require rigorous long-term monitoring regimes. Although many possible environmental impacts can be predicted and minimized by the use of modelling and careful planning, the actual impacts can be determined only by monitoring as development occurs. The monitoring requirements must not be underestimated, either with respect to their scope or their duration. An attempt has been made in this report to indicate the extent to which each of the components of this project (mine, mill, DTMF and road) will require monitoring. We have also indicated that it will be necessary to monitor this project for a far longer time than anticipated in the EIS. The DTMF, in particular, will require perpetual monitoring and arrangements should be made, prior to approval, for the monitoring of this facility in perpetuity.

Approval should be granted only if the returns from the project are expected to be sufficient to bear the estimated costs of monitoring programs that are of adequate scope and duration to fully protect northern residents and the environment, as discussed throughout the report.