cameco - application to revoke the current decommissioning

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StenoTran 1 HEARING DAY ONE 1 Cameco Corporation: Application to revoke the 2 current decommissioning licence, 3 AECB-MFDL-340-0.2, and issue a new licence to 4 possess, manage and store nuclear substances at 5 the Beaverlodge site 6 THE CHAIRPERSON: The next item on 7 the agenda today is Hearing Day One in the matter 8 of the application by Cameco Corporation for a 9 decommissioning licence for the Beaverlodge mining 10 facility -- no, it is to revoke the 11 decommissioning licence -- my notes are wrong -- 12 and for licence to possess, manage and store 13 nuclear substances at the Beaverlodge site. 14 The Notice of Public Hearing 15 2004-H-15 was published on June 29, 2004. 16 August 16, 2004 was the deadline 17 set for filing by the applicant and by CNSC staff. 18 September 8 was the deadline for 19 filing of supplementary information by the 20 applicant and Commission staff. I note the 21 supplementary information has been filed by the 22 applicant. 23 24 25

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Page 1: Cameco - Application to revoke the current decommissioning

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HEARING DAY ONE1Cameco Corporation: Application to revoke the2current decommissioning licence,3AECB-MFDL-340-0.2, and issue a new licence to4possess, manage and store nuclear substances at5the Beaverlodge site6

THE CHAIRPERSON: The next item on7the agenda today is Hearing Day One in the matter8of the application by Cameco Corporation for a9decommissioning licence for the Beaverlodge mining10facility -- no, it is to revoke the11decommissioning licence -- my notes are wrong --12and for licence to possess, manage and store13nuclear substances at the Beaverlodge site.14

The Notice of Public Hearing152004-H-15 was published on June 29, 2004.16

August 16, 2004 was the deadline17set for filing by the applicant and by CNSC staff.18

September 8 was the deadline for19filing of supplementary information by the20applicant and Commission staff. I note the21supplementary information has been filed by the22applicant.23

2425

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04-H23.1 / 04-H23.1A1Oral presentation by Cameco Corporation2

I would like to begin the hearing3this afternoon by calling on Cameco Corporation4for its oral presentation. These are outlined in5CMDs 04-823.1 and 04-H23.1A.6

I will turn it over to Mr. John7Jarrell, Vice-President of Safety, Health and8Environment.9

Mr. Jarrell, you have the floor.10MR. JARRELL: Good afternoon,11

Madam Chair, Commission members, Commission staff,12ladies and gentlemen.13

I am John Jarrell, Vice-President14of Safety, Health and Environment for Cameco15Corporation, as you said. Joining me today is Bob16Phillips who is Manager of Environmental17Protection in the corporate Safety, Health and18Environment Department.19

I should first explain why it is20that Cameco Corporation is here before you today.21

In 1988, the company was formed22from a federal Crown corporation, Eldorado Nuclear23Limited, and a provincial Crown corporation,24Saskatchewan Mining and Development Corporation.25

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Both Bob Phillips and myself1worked for Eldorado prior to the merger.2

In the agreement which formed the3company, Cameco was given the responsibility to4manage the Beaverlodge property subject to an5agreement which described how the business6arrangement would work. Hence, we are the7licensee and are here today before you.8

In the last 20 years the9Beaverlodge site has been in the monitoring and10maintenance phase which is the last phase or11activity in the agreed to decommissioning plan.12

In this plan, closure of the13project is defined as the transfer of the property14to the province. To accomplish this, a 10 year15plan has been prepared. To facilitate this16transfer, a new licence is required.17

By our recollection, the18Beaverlodge project was last formally before the19Commission or its predecessor the Atomic Energy20Control Board in 1983.21

Regulatory activity over this22period has largely taken place at the CNSC and23AECB staff levels.24

You will obviously note that this25

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is a rather lengthy submission and we apologize1for that at the onset. We did so in respect of2the length of time since this project was last3considered by the Commission proper. This is4considered a one time attempt to produce a5document which will prove a useful reference for6future licensing actions over the next 10 years.7

A summary of this presentation is8shown in this slide. We will provide a brief9history of the project to focus our attention on10the decommissioning phase and the path forward.11

The Beaverlodge site is located121,100 kilometres north of Saskatoon. The closest13community is Uranium City, which is connected to14the mine site by a 7 kilometre road. There is no15permanent road into the Uranium City area.16However, during the winter a road is driven17overland from Points North to Stony Rapids and18then across Lake Athabasca to Uranium City.19

During the summer a trail from20Points North to Stony Rapids remains open and from21there a barge to Uranium City can be taken.22Summer barge access from the Alberta side of Lake23Athabasca ceased several years ago.24

Winter road access from the area25

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due south of Uranium City across the lake ceased1many years ago. Access by air remains available2all year round.3

Uranium City had a peak population4of about 2,500 people, which dropped to about 1505people after mine closure. The population dropped6again to about 50 to 75 persons following the7closure of the hospital in 2003.8

Centralized services such as water9and sewage to the community were limited to an10area surrounding the downtown core after mine11closure. Currently, sewage is pumped to a lagoon12which discharges to Cinch Lake located downstream13of Martin Lake, which in turn is downstream of14Beaverlodge Lake, the lake which receives the15drainage from the mine site.16

Potable water is taken from17Fredette Creek, which flows into Martin Lake.18

I feel very fortunate to have Bob19Phillips here with me today. He is Cameco's20manager for the Beaverlodge project and will21present the remaining portions of this22presentation.23

More importantly, Bob commenced24work at Beaverlodge as a mine engineer in 1973 and25

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worked there until 1985. During the period he was1an underground supervisor, chief ventilation2engineer and, finally, environmental protection3engineer.4

During the act of decommissioning5phase, he was responsible for development and6managing the implementation of the plan. Since7the closure of Beaverlodge, he has, amongst other8things, continued to manage the project, so we are9fortunate to have an individual who has been10involved in this operation for over 30 years.11

I will turn it over to Bob.12MR. PHILLIPS: Thanks, John.13This is Bob Phillips, from Cameco14

Corporation.15The operating phase was about 3016

years -- 1951 to 1982. During mining, about 517million tonnes of waste rock was generated, most18of it located around the main underground mine and19mill pictured in this slide.20

Ninety per cent of the ore came21from the main mine, which reached the depth of22about 1,800 metres. The remaining 10 per cent23came from satellite mines.24

The overall grade was about 0.2525

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per cent U-308. The ore was regarded as clean, as1it did not have elevated metal levels associated2with current mines. This was reflected in the3tailings and effluent.4

The ore was alkaline in nature,5thus a mill carbonated leach process was used,6unlike the current mills, which are acid leached. 7

About 21 million kilograms of8yellowcake was packed and flown south. The 109million tonnes of tailings were disposed of by10placing about 4 million tonnes underground to fill11voids left from the removal of the ore and 612million to the tailings management facility, which13was located in the Fulton Creek draining system.14

The satellites consisted of five15underground mines. Two were accessed by shaft,16the Eagle mine and the Hab mine, pictured in this17slide, and the other three were accessed by ramps.18

The mine water from the Eagle and19Hab mines, operated in the fifties and in the20early seventies, respectively, were not treated.21The water from the others were treated.22

The 12 satellite open pits were23mined at various times over the 30-year operating24life. The mining methods used conventional25

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equipment, as shown in this slide. All the1satellite ore, open pit and underground, was2hauled by truck to the mill.3

The current 10-year plan to4delicence and revoke the surface lease has grouped5the satellites as follows: Eagle area, the 02, 466and 11 zones and K-260; the Dubyna area and Hab7area. Each group, in sequence, will go through8the delicence and revoking of surface lease,9starting with the first group.10

The natural Fulton Creek drainage11basin has a total surface area of about 17 square12kilometres. The tailings management drainage area13consists of about six and a half.14

At the end of operations, tailings15from the mill were first pumped to the Dorrclone,16located in the top right-hand corner of the17current slide, where course tailings were removed18for placement underground. The remaining tailings19were then pumped to Fookes Lake, located in the20foreground and characterized by the brown colour.21

The old flow went to Marie Lake,22located in the middle ground, and then the23overflow was treated and discharged to Meadow24Lake, which overflowed to Greer Lake, and then25

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finally to Beaverlodge Lake.1Tailings were not always2

discharged to Fookes Lake. This maps shows where3tails are located. In the early fifties, the4tailings were first discharged to Minewater Lake,5and then to Marie Lake for better settling of the6tailing solids. In the late-fifties, the tailings7discharge point was moved to Fookes Lake, again8for improved settling.9

From the late-fifties to 1982,10Fookes Lake was primary settling and Marie Lake11was secondary settling. The discharge from Marie12Lake was treated for radium-226 removal. Most of13the barium-radium sulphate precipitate was settled14in Meadow Lake, with some carryover to Greer Lake.15Discharge was then to Beaverlodge Lake.16

In 1977, the new Metal Mining17Liquid Effluent Regulations and Guidelines18required the effluent be treated if certain19parameters did not meet the specified criteria.20Radium-226 was the only parameter that did not21meet the criteria. As a result, a treatment plant22was built where Marie Lake discharges, located in23the top left corner of the slide, to the unflooded24Meadow area.25

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The Meadow area provided1insufficient settling for the barium-radium2sulphate. As a result, a dam was built in 19783where the Meadow discharges, located on the bottom4right corner of the slide, creating Meadow Lake,5shown in the slide.6

After the treatment plant was7constructed and before the Meadow dam was built,8barium-radium sulphate precipitate was carried9over to Greer Lake.10

The shutdown of the operation11commenced with the December 1981 closure12announcement. Declining grades, a change in ore13mineralogy and increasing costs were the reason14for the closure. The shutdown phase, December151981 to June 1982, was a time when the operation16was shut down in an orderly fashion, workers and17their families were relocated and testing of18decommissioning and reclamation techniques were19done.20

The salvage phase, July 1982 to21March 1983, saw equipment that was considered to22have value once it was shipped south, cleaned,23checked for compliance with the criteria and then24shipped by truck over the winter road.25

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Immediately following the closure1announcement, preparation of the decommissioning2plan commenced. The plan was approved by the3Joint Regulatory Group, JRG, in August 1983. The4JRG consisted of the Atomic Energy Control Board,5Environment Saskatchewan, Environment Canada and6Saskatchewan and Federal Labour. The plan7consisted of seven primary activities. The first8five are shown on this slide.9

Activity six, implementation of10plan, is summarized in the following four slides.11The mine mill and other operating structures were12demolished and the materials disposed of in open13pits were buried; tailings deltas in Fookes and14Marie Lakes were covered with waste rock; tailings15near the surface in Marie Lake were moved to a16deeper part of the lake during winter; and17barium-radium sulphate sludge in Meadow and18Minewater Lake were moved and disposed of19underground by dumping the material down a raise-20to-surface.21

Tailings spills along the tailings22line: tailing in the Ace Creek floodplain were23removed and disposed underground, other tailings24located at the Ace Creek and tailings management25

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facility watersheds and along the tailings lines1were either covered, disposed underground or left2as is, if location was already stable.3

Decommissioning of miscellaneous4facilities: roads were surveyed for elevated5gamma activity and, where elevated, either removed6or covered. Surface openings from underground7were sealed, satellite mines decommissioned and8the Eldorado town site, pictured in this slide,9was located about half a kilometre from the mill10during the operating phase. Some of the material11from this town site was salvaged and the remaining12buildings were demolished. Currently, a sporting13lodge is located where the town site used to be.14

The approved decommissioning plan15has criteria upon which verification during the16transition phase, activity 7, will be determined.17The criteria consists of requirements and18objectives which are as follows.19

Requirements: total aquatic20loadings during transition phase at Ace Creek21discharge and Meadow discharge to Beaverlodge Lake22shall not be greater than the loadings during the23operating phase. Exposure to workers during the24decommissioning and to the public should be less25

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than the AECB dose limit at the time.1Objectives: Saskatchewan Service2

Water Quality Guidelines and Assigned Uranium and3TDS Guidelines shall apply as objectives at four4sample locations: Ace Creek and Meadow Lake5outlets, Dubyna Lake outlet and Hab mine,6downstream, and Pistol Lake outlet.7

All the sample locations are shown8in this slide and were fully described in our9submission. The locations where criteria are10applied are: TL-7, AC-14, DB-6 and AN-5.11

Note that the majority of the12satellite and Fay mine, the mill areas drained to13the Ace Creek system. The tailings management14facility is located in the natural Fulton Creek15system.16

The transition phase is about,17currently, 19 years -- 1985 to 2004. It is18projected to go to the year 2012, as per the1910-year plan. Verification of the plan for20ongoing performance has been assessed in the21annual reports and the site environmental effects22reassessment. The following before-and-after23pictures give a visual perception of their24performance.25

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The before operating mill and main1mine, in background, versus the after2decommissioned site: note the grey concrete pad3in the after picture, located to the left, in the4middle of the picture. That is the pad for the5yellow-sided building in the picture above.6

The before operating tailings7managements facility, located in the Fulton Creek8drainage and the after decommissioned TMF; the9before waste rock area, just after completion of10decommissioning in 1985 and the after, the same11general area.12

Water quality performance at13Meadow Lake discharge is summarized as follows:14all metals, total suspended solids and pH meet the15objectives. Iron is, at times, slightly above16objective. Radium-226, uranium and TDS are17greater than the objectives. There is a18decreasing trend for uranium and TDS and an19increasing trend for radium-226 at both Meadow20Lake discharge, TL-7 and Greer Lake discharge to21Beaverlodge Lake, TL-9.22

From a site environmental23reassessment, February 2003, it was shown that the24radium-226 increase at Greer Lake discharge was25

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due to the redissolution of barium-sulphate in1Greer Lake and the increase at Meadow Lake2discharge was due to flows from Minewater Lake.3

Radium-226 and uranium4concentrations, based on the recent reassessment,5were not predicted to meet objectives until 21506and 2300, respectively. TDS concentration is7predicted to meet the objective in the next five8years.9

Note the downward trend in total10dissolved solids TDS concentrations. It was11predicted in the recent risk assessment that the12objective would be met in the next five years.13Also note the uranium downward trend at Meadow14Lake discharge, TL-7, and Greer Lake discharge to15Beaverlodge Lake, TL-9; however, meeting the16objective is predicted to not occur until 2300.17

Decommissioning was completed18during the period 1984 to 1985 in the tailings19management facility. Prior to this period, the20effluent was treated and, therefore, the21radium-226 level at TL-7 was at its lowest.22Following the 1984-85 period, there was no23treatment, and therefore the radium-226 level from241984-85 to 1992-93 gradually increased to the25

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level in Marie Lake, the upstream feed to TL-7. 1Marie Lake, during the operating2

period, was a secondary settling lake for the3tailings prior to treatment for radium-2264removal. From 1992-93 to 2001-02, the level at5TL-7 reflected the level from Marie Lake, and6therefore was relatively consistent. For the last7two years, at TL-7, the level not only reflected8what was coming from Marie Lake, but also seems to9be reflecting what is coming from Minewater Lake.10

This lake flows into the area just11upstream of TL-7 and was used during the operating12phase to settle barium-radium sulphate precipitate13from the treatment of mine water. The cause of14this apparent increase is being studied.15

The discharge from Greer Lake,16TL-9, to Beaverlodge Lake is located downstream of17Meadow Lake, discharge TL-7. The changes at TL-718did not take effect at TL-9 until about 1990-91. 19

From this period to the present,20the level has been higher than at TL-7 and the21trends at both locations have been about the same.22The higher levels at TL-9 have been due to23redissolution of the barium-radium sulphate24precipitate that was carried over to Greer Lake25

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from the upstream treatment process, which used1Meadow Lake for precipitant settling during the2operating period.3

The reassessment of Fulton Creek4water quality has predicted that radium-226 levels5at TL-7 and TL-9 will begin to decline in the near6future and that the objective will be met at TL-77around 2150.8

The Ace Creek drainage during the9operating phase received flows from most of the10satellite mines and included run-off from the main11mine and mill. All of this was, and still is,12reflected at the Ace Creek discharge to13Beaverlodge Lake, AC-14.14

Currently, all parameter levels15are less than the objective. Uranium dropped16below the objective in 1982 to 1983, following the17closure of the mill. It was quite apparent that18the mill, during the operating phase, was having a19significant effect on Ace Creek. The observation20mentioned for uranium also applies for radium-226.21

The former Dubyna mine discharge22treated effluent to Dubyna Lake was discharged to23Ace Creek, called DB-6. Ace Creek at this24location was upstream of the main mine and the25

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mill. All metals, radium-226 and TDS, are less1than their respective objectives. The one2exception is uranium, which is greater than the3objective; however, the trend is decreasing4levels.5

The state of the environment at6Dubyna Lake has been assessed as part of the710-year plan to delicence. It was determined from8this assessment that the reason for the higher9uranium level was believed to be mine water10discharges by bore holes to Dubyna Lake. The plan11is to attempt to locate and plug the holes.12

Radium-226 at Dubyna Lake13discharge, DB-6, has been consistently below the14objective, as shown in the slide. Uranium levels15are slightly above the objective, but the trend is16decreasing.17

The former satellite Hab mine18discharged untreated effluent to the Pistol19Lake/Mickey Lake drainage system, which drains20into Ace Lake and then into Ace Creek. Levels for21all metals and the total of all solids are less22than the objectives. The exceptions are uranium,23which at times is above and below the objective,24and radium-226, which is routinely above the25

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objective.1The reason for uranium and2

radium-226 being above their respective objectives3is believed to be mine water discharges by bore4holes to Pistol Lake, based on preliminary5assessments.6

As shown in this graph, the7radium-226 level is above the objective and8variable. As indicated, uranium levels are, at9times, above and below the objective.10

One of the decommissioning11requirements was that the total loadings during12the transition phase to Beaverlodge Lake from both13Meadow Lake discharge, TL-7, and Ace Creek, AT-14,14would be no greater than the loading during the15operational phase.16

The operational phase loading was17calculated using the revised mean predicted flows18and the actual mean parameter concentrations from19the operating period 1977 to 1982. The20transitional phase loadings, determined using21actual flows and parameter concentrations, were22less than the operational phase loadings. The23parameter that came closest to the operational24phase loading was radium-226.25

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The total actual radium-2261loading to Beaverlodge Lake over the period21998-99 to 2003-04, shown by the green variable3line, is consistently below the straight green4line, representing the operational loadings.5

Two environmental risk assessments6have been done. The original 1983 environmental7risk assessment was done in support of the8decommissioning plan. The second 2003 assessment9was done in preparation for relicensing and to10determine whether, after almost 20 years, the11original predictions were still valid. This12assessment had additional components, an13ecological and terrestrial assessment and human14health assessment.15

The major environmental findings16of the assessment were as follows: radiation17unlikely to affect aquatic species, such as fish18and benthic and terrestrial species, such as19caribou, eagle, hare, grouse, moose and muskrat.20

Selenium in the water may affect21some fish species by their ability to reproduce22and may effect ducks and muskrats.23

Uranium levels exceed benchmarks24for algae and zooplankton.25

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At this time, I would like to1mention two corrections for the record.2

In the current slide, it indicates3that ecological risk assessment, selenium and4uranium concentrations exceed benchmarks for algae5and zooplankton. It should be only uranium.6

Number two, in the August 16, 20047CMD submission, page 27, second paragraph, it8should read: In regards to uranium the predicted9concentrations exceed the toxicity benchmarks for10primary producers and zooplankton in Greer,11Beaverlodge and Martin lakes.12

Our response to these13environmental findings are as follows.14

Selenium: studies are being15conducted at our operating sites to assess effects16on aquatic and terrestrial species.17

Muskrat: field presence/absence18assessment in the former TMF area is being19conducted over 2004 and 2005.20

To reduce uncertainty in the21modelling, selected species will be analyzed for22parameters of concern during the scheduled 10-year23plan studies.24

As part of the 10-year plan,25

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conduct a cost/benefit analysis of possible other1rehabilitation options which may further reduce2impacts.3

With regard to the human health4effects, the assessment identified potential5exceedances of selenium and uranium toxicity6benchmarks for a person living on the shore of7Beaverlodge Lake and Martin Lake.8

Uranium exposure was primarily due9to the consumption of water and the selenium10exposure primarily due to the consumption of fish.11

Radiological exposure estimates12were well below the current public level for a13public limit of 1 millisievert per year.14

Our response to the findings are15as follows.16

The Saskatchewan Human Health Unit17in La Ronge was contacted to discuss the above18findings. From this meeting, it was decided to19meet with the people in Uranium City through a20public meeting and personal one-on-one meetings to21discuss the risk from eating the fish and drinking22the water.23

Since then the Province of24Saskatchewan has put out a notice to the public25

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regarding the consumption of fish and water.1The original decommissioning plan2

addressed the implementation of the plan and the3transition phase which we are currently in. It4did not consider the delicence and the surface5lease revocation which would bring closure to the6site.7

As a result, a 10-year plan was8prepared and submitted with summarized activities9proposed for the return of areas to the province10revoking the surface lease.11

The proposal seeks closure of12selected areas at different times over the next 1013years. It will start with minor satellites14following by major satellites, Dubyna and Hab, and15ending with the main site.16

The current status of the plan is17as follows.18

Application has been made to bring19closure to the minor satellites.20

Environmental assessment of the21Dubyna area has been completed.22

Environmental assessment of the23former TMF has commenced.24

A preliminary assessment of Ace25

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Creek has commenced.1Annual public meetings have been2

held in Uranium City since 2001. The purpose of3the meetings were to inform the public with4regards to current information, progress in5regards to delicensing and surface lease6revocation, describe new activities and receive7feedback and answer questions.8

At the meetings are also9environmental quality committee representatives.10These people have been nominated to represent11their communities at public meetings.12

The most recent meeting was held13April 2004.14

A special public meeting was held15September 9, 2004 to give local residents this16presentation and receive feedback.17

In addition, this presentation was18given to the EQC and the Northern Mine Secretariat19this morning as they were unable to attend this20afternoon's session.21

It was noted at the beginning of22this presentation Cameco was formed from the23merger of provincial and federal uranium24companies. The terms of the agreement that relate25

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to financial assurance were that Cameco is1responsible for the management of the site and2Canada Eldor Inc., a federal Crown agent, is3responsible for costs and recognition of the site4status at time of merger.5

Canada Eldor Inc. is a subsidiary6of the federal Canadian Development and Investment7Corporation, an agent of the Government of Canada.8

Cameco has approached CDIC through9Canada Eldor Inc. requesting documentation to show10that they are responsible for the costs associated11with the Beaverlodge project.12

I am now going to turn the13presentation back over to John Jarrell for the14summation.15

MR. JARRELL: Thank you, Bob.16It has been a relatively long17

journey to get to this point in the life of this18mining facility. We have a current plan which19could see complete CNSC licence release for all20Beaverlodge properties over the next 10 year21period.22

We believe we have managed the23property in a manner consistent with the24responsibilities transferred to us at the time the25

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Cameco Corporation was formed in 1988. Broadly1speaking, the decommissioning work carried out2immediately after the mine was shut down has3proven effective.4

Forecast impacts, while going from5an effluent treatment to no active effluent6treatment has generally met predictions, and after7close to 20 years we believe environmental8behaviour is both well understood generating9evidence of a return to premining states. This10evidence of a recovering ecosystem is no doubt11greatly assisted by the fact that Beaverlodge ore12was relatively clean ore.13

In recognition of efforts to try14to get this project beyond its current15transitional phase monitoring and in recognition16of changing societal expectations, Cameco has17stepped up its public consultation efforts over18the past few years.19

It may also be that20decommissioning expectations have also changed21over the past 20 years. While we think it22important to respect past agreements, we also23recognized the need to meet current expectations24in a manner which is both cost-effective and25

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environmentally responsible. We remain committed1to pursuing these goals and our management of this2facility on behalf of ourselves and our government3partners.4

We have taken what might seem a5counter-intuitive move for a licensee in asking6for a shorter rather than a longer licensing7period. We do so because two years seems like the8logical duration given the progress which is being9made in ongoing provincial and federal10institutional control policy discussions.11

However, at the end of the day we12continue to need a licence to possess, manage and13store nuclear substances associated with the past14operation of the facility and consequently are15here today before you seeking renewal of our16licence, albeit in a somewhat different form than17the current licence.18

Thank you for your attention.19Hopefully this will prove to be a one-time rather20extensive brief structured to cover the site21history over the past 20 years as well as our22future plans.23

This completes our presentation.24We are prepared to answer any questions now or25

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later in the hearings.1Thank you.2THE CHAIRPERSON: Thank you very3

much.45

04-H236Oral presentation by CNSC staff7

THE CHAIRPERSON: Now we are going8to turn to the CNSC staff for their presentation9as outlined in CMD 04-H-23.10

Mr. Howden, you have the floor.11MR. HOWDEN: Thank you.12Good afternoon, Madam Chair and13

members of the Commission. For the record my name14is Barclay Howden. I am Director General of the15Directorate of Nuclear Cycle and Facilities16Regulation.17

With me today are Mr. Kevin18Scissons, Director of the Uranium Mines and Lands19Evaluation Division, Dr. Patsy Thompson, Director20of the Environmental Protection and Audit21Division, and the rest of the CNSC licensing team22for this facility.23

Cameco Corporation has submitted24an application for a licence to allow for the25

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possession, management and storage of nuclear1substances at its Beaverlodge decommissioned mine2and mill site in northern Saskatchewan. This3licence would replace the current decommissioning4licence, AECB-340-0.2, which would be revoked.5

The proposed licensing changes are6essentially administrative in nature and do not7involve any new physical works or changes to the8substance of the existing licence, or any other9obligations under the existing licence or under10the Nuclear Safety and Control Act and its11associated regulations.12

In this document, Canadian Nuclear13Safety Commission staff recommends that the14Commission make a licensing decision on the15application pursuant to section 24 of the Nuclear16Safety and Control Act.17

I will now ask Mr. Scissons to18present CMD 04-H23.19

MR. SCISSONS: Good afternoon,20Madam Chair and Commission members. I am Kevin21Scissons, the Director of the Uranium Mines and22Lands Evaluation Division.23

Today's presentation will address24the seven topic areas noted on this slide, which25

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is mainly the site description, the licence type1and period, the review of the application, public2interest, the Canadian Environmental Assessment3Act, the cost recovery and staff's conclusions and4recommendations.5

The site to be licensed. Cameco6currently possesses an AECB mine facility7decommissioning licence for the Beaverlodge site8located near Uranium City, Saskatchewan.9

Decommissioning was completed by101985 and since that time the site has been in a11monitoring and maintenance phase based on the12closeout objectives agreed to by the joint13regulatory group at that time.14

The JRG included Environment15Canada, Fisheries and Oceans Canada, Saskatchewan16Environment, Saskatchewan and Canadian Labour and17the AECB staff.18

All mine and milling structures19have been removed from the site and mine shafts20have been capped and decommissioned according to21CNSC requirements.22

There are no major physical active23facilities or works associated with this site.24

There are three water level25

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control structures but no effluent treatment1plants.2

There are roads, waste rock piles3and tailings management areas that are subject to4both government and company inspection programs as5well as local and area-wide environmental6monitoring programs.7

The Beaverlodge site contains8three tailing management areas, that along with9the uranium tailings that were disposed of10underground contain a total of approximately 1011million tonnes of uranium mine tailings.12

There are approximately 5.113million tonnes of waste rock on the site, and this14is in relation to a very low grade mine operation15by today's standards.16

The site consists of 73 separate17properties covering approximately 744 hectares.18The facility is described in more detail in19Cameco's licensing submission.20

The activities proposed to be21licensed are to possess, manage and store nuclear22substances at the Beaverlodge site near Uranium23City. These activities were previously authorized24as part of the more general decommissioning25

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activities under the original AECB licence issued1on September 1, 1982.2

Management of nuclear substances3includes regular site inspections, regular4environmental monitoring and any special5environmental investigations deemed appropriate6and necessary in consultation with CNSC staff and7the other regulatory groups.8

No waste will be added to the9decommissioned properties, no additional10structures are proposed and no effluent treatment11is proposed.12

It is Cameco's intent to reclaim13as many of their properties as possible for14eventual release to the province of Saskatchewan15under some form of long term institutional care.16Such institutional care would include monitoring17and possibly maintenance at a level appropriate to18the risk posed by the reclaimed land.19

The institutional care would20prevent unrestricted use of the land in the21future.22

The province is planning to23finalize their draft policy on institution control24in the fall of 2004. There is no planned release25

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of any properties at this time.1The applicant requested the2

issuance of a licence to possess, manage and store3nuclear substances associated with past operation4of the decommissioned Beaverlodge mining and5milling facility. Since the inventory of6radionuclides of the site exceeds 1015 becquerels7and all decommissioning activities described in8the decommissioning plan have been completed, CNSC9staff has concluded that a waste facility10operating licence is the most appropriate type of11licence for this facility.12

A decommission licence is no13longer required as the physical decommissioning14activities have been completed. This15administrative change to a WFOL is also similar to16the licence type change for the decommissioned17Elliott Lake uranium mines.18

The licensee has requested a19licensing period of two years. It is the20intention of the licensee to apply for a renewal21at that time. By that time it is anticipated that22the process will be better understood for Cameco's23plans to transfer some of the lowest risk24properties included in the CNSC licence to the25

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province of Saskatchewan under institutional1control pursuant to the CNSC's approval.2

The review of the application.3The licensee has indicated that4

there will be no changes to the facility, the5inspection and monitoring programs or the6operational management structure as it relates to7the existing licence in the closeout objectives8agreed to by the joint regulatory group at the9time of closure in 1985.10

CNSC staff considers that the11information submitted by the applicant meets the12requirements of the CNSC regulations.13

In terms of the licensee's14performance, Cameco achieved a B rating for15program design and performance in the following16control areas: environmental monitoring program,17radiation monitoring, operations and maintenance,18organization and management, public information19programs, security and safeguards.20

Cameco has met all of its21obligations under the described monitoring program22submitted and submitting all required reports on23time.24

Communication to CNSC in the joint25

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regulatory group or JRG has been timely and any1events which impact the site have been promptly2reported.3

Requests from regulatory agencies4have been dealt with in a timely manner. Some of5these requests have required ongoing review by the6JRG. The JRG for the Beaverlodge site today7includes: Environment Canada, Fisheries and8Oceans Canada, Saskatchewan Environment and CNSC9staff.10

No physical activities or11remediation have been required in the last five12years other than maintenance. In the event that13any physical works or new construction activities14are proposed or required, they would be assessed15based on our current obligations under the NSCA16Act and the Canadian Environmental Assessment Act.17

The licensee did assess and18perform final clean up to meet the JRG and the19provincial standards, conventional health and20safety, of the five decommissioned satellite mines21from 1999 to 2003.22

This underwent continual public23JRG information and consultation and was done with24the intent of seeking eventual release from25

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licensing for eventual institutional control with1the province.2

Financial guarantees. Cameco3currently manages the site under a cost recovery4agreement with Canada Eldor Inc., a wholly owned5subsidiary of the Canadian Development Investment6Corporation, which is a federal Crown corporation.7

CNSC staff is assessing further8Cameco's financial guarantee proposal.9

In addition, CNSC staff have been10advised that confidentiality of information may11require that the reference to the agreement for12the purchase and sale of assets to Eldorado13Nuclear Limited, which is listed in Appendix B of14the licence, of the draft licence, may actually15have to be removed.16

In the event that CNSC staff may17not have the financial guarantees issue fully18resolved, part of the Public Hearing Day 2, staff19can propose a new licence condition requiring a20financial guarantee be put in place by a set date21for this decommissioned facility.22

CNSC staff will report to the23Commission on the status of this issue on or24before Public Hearing Day Two.25

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With the exception of the1Saskatchewan Northern Mines Environmental Quality2Committee, there have been no expressions of3public interest concerning Cameco's Beaverlodge4site within the previous 24 months and to date no5significant interest in relation to this6application.7

The EQC's interest in the8Beaverlodge site has been primarily in assuring9local contracting for monitoring and maintenance10work and continued site access for hunting and11recreational purposes. As the site was12decommissioned with the intent of allowing public13access, CNSC staff has no concerns with people14making limited use of access on or across the15site.16

In addition, during recent17discussions with the EQC on site inspection this18summer, we also discussed implications of19concentrations of the radium-226 reporting20downstream to Beaverlodge Lake and some21discussions on the uptake of uranium in moose.22

Generic interest in other northern23Saskatchewan idle or Legacy mine sites has been24reflected on Beaverlodge, but does not necessarily25

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usually name that site specifically for those1concerns.2

In addition, Cameco has a3corporate program on public consultation,4including information sessions throughout northern5Saskatchewan. The program has been previously6assessed for other uranium mines like McArthur7River, Key Lake, Rabbit Lake and Cigar Lake. CNSC8staff has found this program adequate.9

In addition, Cameco holds an10annual public meeting in Uranium City to provide a11status report on all activities specifically12related to Beaverlodge. CNSC staff attends this13meeting and provides a regulatory perspective on14ongoing monitoring and maintenance at the site.15We attend this meeting in conjunction with16Saskatchewan Environment as well.17

Based on an assessment by CNSC18staff, the public information program submitted by19Cameco Corporation for the Beaverlodge20decommissioned mine and mill site application21meets the criteria for an acceptable public22information program set out in draft regulatory23guide C-217 and meets the requirements in24paragraph 3(c)(i) of Uranium Mines and Mills25

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Regulation.1Canadian Environmental2

Assessment Act.3The CNSC is not required to4

conduct an environmental assessment under CEAA5because the proposal is captured by6subsection 74/4 of the CEAA, a transition clause.7CEAA does not apply to projects initiated before8June 21, 1984, therefore the CNSC is not required9to conduct an environmental assessment under CEAA10before considering the issues of a licence for11Beaverlodge as a project and the current12activities with it were initiated in 1982.13

Cost recovery. Cameco Corporation14is in compliance with the CNSC's cost recovery15regulations of 2003.16

CNSC staff concludes that Cameco17Corporation is qualified to carry out the18activities that the licence will authorize and19will make adequate provision in carrying out that20activity for the protection of the environment,21the health and safety of persons and the22maintenance of national security measures required23to implement international obligations to which24Canada has agreed.25

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CNSC staff recommends that the1Commission accept the assessment of CNSC staff2that an environmental assessment under the CEAA is3not required to be carried out by the CNSC staff4for the issuance of the proposed waste facility5operating licence and revocation of the current6decommissioning licence; and7

accept the assessment of CNSC8staff that Cameco Corporation is qualified to9carry out the activities that the licence will10authorize and will, in carrying out those11activities, make adequate provision for the12protection of the environment, the health and13safety of persons and the maintenance of national14security and measures required to implement15international obligations to which Canada has16agreed; and17

pursuant to section 24 of the18Nuclear Safety and Control Act, issue to Cameco19Corporation the waste facility operation license20WFOL-W5-2120.0\2006 for a two-year licence term;21and concurrently with this licence coming into22effect, revoke licence AECB-MFDL-340-0.2.23

Thank you.24MR. SCISSONS: Madam Chair, that25

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finishes off our presentation and we are available1to respond to questions.2

THE CHAIRPERSON: Thank you3very much.4

Are there any questions?5Mr. Graham.6

MEMBER GRAHAM: I have a couple of7questions. A very, very thorough presentation by8both groups and I want to thank them.9

In your very last slide you say to10issue a "Waste Facility Operating Licence". That11is not quite the same wording as we have "licence12to possess, manage and store nuclear substances"13is what the heading was on this.14

Does that mean the same thing?15MR. SCISSONS: It's Kevin16

Scissons.17Yes, it is. Those activities18

would be captured by that specific licence title,19yes.20

MEMBER GRAHAM: Two other short21questions.22

Monitoring the site over a period23of time, because there will be water samples and24monitoring done over the next 10 years, that cost25

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is borne by whom?1MR. SCISSONS: It's Kevin2

Scissons.3The licensee, Cameco, is4

responsible for that monitoring program and has5fulfilled that monitoring program since the6close-out of the facility.7

MEMBER GRAHAM: Does CNSC do any8of that work under cost recovery?9

MR. SCISSONS: The monitoring10work? We do not do any of that monitoring work,11though there are times during our annual site12inspections with the joint regulatory group we13have, on occasion, collected water sample to14confirm, as does the province very routinely in15collecting samples. That is part of our16regulatory compliance program.17

MEMBER GRAHAM: You also mentioned18that there are three water structures. Just the19structure itself, is there any maintenance20required on those? If something happened, a flood21took them out, does it cause any problems to the22environment or to health and safety of people?23

MR. SCISSONS: It's Kevin24Scissons.25

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The structures are actually1located at the end of basically two water bodies,2lakes, and one water course. There is an existing3damn facility that Mr. Phillips mentioned was4actually built in 1978.5

The retaining structures behind6have actually been removed. The structure is7there and it can be physically removed or not. It8is not retaining any water, it has no purpose9behind it to hold or retain water or solids. It10is there as a concrete, solid structure and there11is very little maintenance that would be required12on that.13

The other two structures at the14outlet of both Fookes Lake and Marie Lake which15contained tailings, they are very minimal16structures of a height of 1 to 2 metres, but they17are constructed and rip-wrapped and concreted in18place. There is very little maintenance expected.19

There is a very low head of water20behind it, but it is more of a condition required21to ensure there is adequate water cover of the22tailings behind and retained in those lake basins.23

So they are there mostly to manage24the flows of the variations in flows, annual peak25

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flows that would occur in there, but the1engineering structures are assessed, I believe2every two to three years, by a contractor, by3Cameco, as well as staff will routinely go up.4Our period is maybe about every five years to5assess these very minor structures to confirm6their integrity.7

In the long term we would expect8very little maintenance would be required for9them, but they would be borne either under10institutional control with the province or with11the licensee as being necessary.12

MEMBER GRAHAM: In other words,13they will be tracked over the period of the next1410 years but also when they are turned over to the15province, if the province takes over those16specific parcels of property, that they will17ensure that there will be maintenance?18

MR. SCISSONS: Yes. Whoever will19be responsible for those tailings over the long20term will be responsible for the maintenance of21those structures and that will be one of the22obligations of staff in our recommendations to23whomever is left with that licensing24responsibility, whether it is Cameco or in the25

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future if the Province of Saskatchewan takes over1responsibility for those tailings basins, yes.2

MEMBER GRAHAM: The next question3I have, the only other question I have, I need a4little direction and that is with regard to5radium-226. You indicated that there are two6bodies of water that were above, I believe, or two7areas that were above the objectives.8

Just for my knowledge I would like9to find out how serious is that as far as10affecting the environment in any way or safety to11the health and safety of people or the12environment?13--- Pause14

DR. THOMPSON: Patsy Thompson, for15the record.16

The close out objectives were set17in relation to the then operation, essentially the18releases at the end of the operation. We have19since looked at trends and loadings and20concentrations of contaminants.21

The trends are of concern in the22sense that we would like to understand what will23happen in the long term so that we can make proper24decisions and recommendations to the Commission,25

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but in the short term, in terms of public health,1the public health concerns are quite limited2because site access is limited and site use is3limited. So from that point of view the potential4health effects of exposure to radium are5negligible.6

In terms of potential7environmental effects, for the same reasons8concentrations are a concern in terms of9understanding the behaviour and the potential10trends, but in terms of actually affecting biota11resident in those areas the risk is also12negligible.13

MEMBER GRAHAM: The only other14question I would have is: In the information15sessions that are given yearly at Uranium City and16so on, the local population are made aware of the17two areas that are above and what they should be18careful of.19

Is that correct?20MR. SCISSONS: It's Kevin21

Scissons.22Yes, they are. The meetings are23

held there and in special cases the province, the24provincial Department of the Environment and25

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Health have actually gone out to visit residents1near these areas farther downstream from the water2bodies to make sure they talk with them3specifically.4

So yes, there have been extensive5measures to make sure it has been well6communicated with them and it is very much local7knowledge of the facilities. Yes.8

THE CHAIRPERSON: Dr. McDill.9MEMBER McDILL: I think my10

questions are a good follow up to Mr. Graham's.11Can you remind me what the12

drinking water and groundwater guidelines are for13uranium and -- becquerels per?14

THE CHAIRPERSON: If the licensee15knows, that's fine.16

MR. JARRELL: John Jarrell, for17the record. I will ask Bob Phillips. I know the18radium objective is .11, but maybe Bob could give19you just a summary of our objectives that we use.20

MR. PHILLIPS: Bob Phillips here,21for the record.22

The objectives which form part of23the plan are for radium it is .11 becquerels per24litre, which is the same as the Saskatchewan25

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surface water quality objective.1For uranium, as part of the plan2

it is 250 micrograms per litre. But you asked for3drinking water. I believe the level is420 micrograms per litre right now. That is the5federal and the province has adopted that as well6for drinking water.7

MEMBER McDILL: I saw Dr. Thompson8nodding.9

DR. THOMPSON: Nodding doesn't go10very well on the record. This is Patsy Thompson.11

For the record, the drinking water12guideline is indeed 20 micrograms per litre.13

But just as maybe additional14information there is no groundwater limits in15addition to the drinking water guidelines. The16issue of groundwater contamination, we are using17the assessment methodology in terms of preserving18the use of groundwater when it is used as drinking19water source.20

In this case the groundwater21on the Beaverlodge site is not used as groundwater22but the surface water guideline would then apply23for surface waters that are used for drinking24water.25

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MEMBER McDILL: Thank you. My1other question was related to the population of2Uranium City. This is probably to Cameco. I have3two questions.4

Can you describe the population of550 or so still left in terms of their interest in6the annual meeting and their general wellbeing?7

Who is responsible in terms of8standard health and safety for the sewage that is9going into the lake. It sounds like it is raw10sewage. Who is responsible for that in terms of11Uranium City?12

MR. PHILLIPS: Bob Phillips here13from Cameco.14

With regards to the public15meeting, the one in April we had 10 people attend16out of a population of about 50 people. The one17that we had in April -- that is April.18

The one we just had this month we19had five people who showed up. Of those five, one20was the mayor, there are two counsellors and two21interested citizen. One of them manages what they22call the Bible Camp. In Uranium City the Baptist23Church runs a Bible Camp on Ace Lake. This year24it brought in about 104 kids so she was quite25

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interested in knowing what the health aspects were1so we were answering a lot of her questions.2

With regards to the sewage system,3that falls under the Saskatchewan laws and rules4and how that is managed.5

MEMBER McDILL: It is the6responsibility of the municipality then.7

MR. PHILLIPS: Yes. Yes, it is.8I'm sorry.9

THE CHAIRPERSON: Mr. Taylor.10MEMBER TAYLOR: Thank you, Madam.11

Just one question.12In the Cameco submission it talks13

about an investigation that has to be done into14conditions in some water bodies which is to be15expected to be published in January 2005.16

Has the staff had any input into17the nature of this investigation? Will it go some18way to satisfy the remaining concerns that you19have about long-term behaviour and will the20results of that be eventually passed on to the21Commission?22--- Pause23

THE CHAIRPERSON: Is that a Cameco24study? Why doesn't Cameco reply.25

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MR. PHILLIPS: It is Bob Phillips1here from Cameco.2

As part of our 10-year plan to3de-licence and revoke the surface lease we have a4number of studies that we will be planning to do.5I believe one of the studies that you are6referring to is a study on the former tailings7management facility.8

The study involves assessing, I9guess, the environmental health of that system,10looking at the Fookes Lake, Marie Lake, looking at11fish that are presently in there, benthics,12sediment quality, macrophytes. What we are hoping13to be able to do over the 10-year period is track14the health of the system over time.15

Ideally what we would like to be16able to say is that the health of the system is17improving. With that in mind, it may help us18support release of that property back to the19province.20

MR. SCISSONS: Kevin Scissons.21We have had direct input to JRG22

and CNSC staff into a number of monitoring23programs and studies through the years at the24site. This one is no different. We have had some25

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participation in that and input on it.1We are waiting of course for it to2

be fulfilled and confirmed the components.3Yes, we will be reviewing it and4

giving the feedback to the licensee if there is5any more follow up with it. I believe there are6plans of course for it to have wider distribution7through the members of the public in there in the8affected area and we can make sure it gets to the9Commission, if not sooner clearly before the next10licensing term, but it won't be on the table11before we go through Day 2 for this facility.12

MEMBER TAYLOR: Thank you.13THE CHAIRPERSON: Dr. Dosman.14MEMBER DOSMAN: Thank you,15

Madam Chair. I have several short questions.16I find it fascinating to see, if17

you like, the 20 year history of the closure of18decommissioning of a relatively modern facility.19In that context I would just like to ask: After20the property is returned to the government or21Saskatchewan, Mr. Jarrell, do you have any22estimation of the number of years that will be23required for the authorities in Saskatchewan to24monitor the site? What are they looking at down25

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the line?1MR. JARRELL: John Jarrell, for2

the record.3I think at this point obviously4

there is a fair amount of speculation in that.5What we provided in our presentation was an6estimate of some of the return to sort of the7objectives and they go out a fairly long period of8time.9

Of course, what you generally get10in these responses is sort of an exponential-type11response where at the end you get very, very slow,12gradual response.13

I think our expectation is14probably some variable level of institutional15control going forward. We have not had those16discussions with the province yet, largely I think17because the policy framework hasn't been18established yet.19

My expectation is that obviously20there has to be some accommodation of the future21monitoring costs, licensing costs -- not licensing22costs, but certainly monitoring costs and23maintenance costs of these facilities. That24negotiation hasn't occurred yet.25

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The overall sort of our business1plan, if you will, I think is just to take the2simplest ones first or the walk before you run3type approach. So we are taking what we think are4the simplest parts of our operation, which are the5remote satellites, and try to reach resolution and6try to develop a template with the province for7this.8

My current expectation is that we9may very well see different arrangements for, for10example, satellite mines. Some of the larger11satellite mines Hab and Dubyna, and of course the12main event which is the main mine site. I expect13that that will be a very different arrangement14than the one we penned for the very first one.15

MEMBER DOSMAN: Thank you. Just a16minor point. Is there will activity going on in17the sporting lodge and are the managers or guests18at any risk from the site?19

MR. JARRELL: John Jarrell.20No, it is still an active sporting21

lodge. I will ask Bob Phillips, who probably22stayed there just a few weeks ago so he maybe can23give you a sense of how the operation works.24

MEMBER DOSMAN: I will ask how25

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the food was.1MR. PHILLIPS: Bob Phillips here2

for the record.3The reason we stay at the sporting4

lodge is to support local communities, but also it5is very close to the former site so it is very6easy access. They have trucks for rental and7things like this, so it helps out a lot.8

It is a well used lodge. They get9people up from the states, from the rest of Canada10and from overseas. Most of the fish is caught on11what they call a catch and release. It is a12Saskatchewan program to return the trophy back to13the waters to be recaught again, so a lot of the14fishing is done in Beaverlodge Lake but more so in15Lake Athabasca where the big trophies are.16

I am sorry. Just one more point17that John reminded me.18

The water supply for the lodge,19they get it from a well. The actual former20Eldorado town site and the lodge is built on a21very large sand esker from the glaciation period22and it channels a lot of groundwater through this23esker area, sand. They have actually developed a24well in that area and the water has been tested25

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and found to be quite good.1MEMBER DOSMAN: Madam Chair, I2

would just like to ask a question of Mr. Jarrell.3As this is now a 20 year history4

of decommissioning, and as other decommissionings5will be coming up, in the area of lessons learned6are you learning about things you might do and7other areas that you didn't do and so on?8

MR. JARRELL: John Jarrell, for9the record.10

Yes, I think there are some.11Probably technically the largest issue I take away12from this is the stability of barium-radium-13sulphate precipitates in the long haul.14

The other lesson learned I think15is the importance of setting the criteria at the16time of decommissioning very clearly. We17struggled a bit on this one from the point of view18of the overall objective was to match, at least19match, the current period loadings during the20decommissioning phase or sort of the transition21phase which may seem obvious but of course we are22doing it with a water treatment. So we23established a criteria that ultimately set our24standard.25

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The one difficulty we found is1that we hadn't probably collected enough2information as a baseline and as a consequence,3when we started to do sort of a detailed4comparison with respect to the standard, we found5we were sort of the prisoners of the amount of6work which had occurred in the past. So we7actually had to go back and actually collect quite8a bit more water flow information to support that.9

So I think one of the lessons10learned is to make sure that you have a very good11baseline.12

The other lesson, as I said, is13really that of the stability of the barium-radium14precipitate.15

The third I think is the value of16public consultation. We have put some effort over17the last five years to really engage the people18most involved. Having watched a few of these go19along the lines, I think that has made some fairly20significant evidence so far.21

THE CHAIRPERSON: Dr. Barnes.22MEMBER BARNES: Just a few23

residual questions as the day grinds on.24Page 12 of your 45, just above the25

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last section that refers to the Eldorado town1site, the paragraph before that which is the2second paragraph under other satellite mines, you3said that only one satellite open pit was not4filled because you didn't have enough waste rock.5As a result, the pit filled with water creating a6pond with no surface outflow.7

Have you any idea whether there is8a progressive increase in contaminants in that9pond or is that so small that you haven't done any10analyses on it?11

MR. JARRELL: John Jarrell for the12record.13

Actually not. That actually was14one of the cause celebs when we looked at this15because the water was slightly over the water16quality objectives. I think collectively we were17working with this as to how do you disposition18this.19

I am going to ask Bob Phillips20maybe to give you a little bit of the history of21this. It is a very small pond, but I think it was22important issues I think to discuss when we23discussed this with the regulatory agencies.24

MR. PHILLIPS: Bob Phillips for25

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the record here.1To go back to the decommissioning2

period, there was insufficient waste rock in the3area, mainly because the mine was mined on ore, so4there was very little waste rock so when it came5time to fill it up we weren't able to do that. As6a result, it filled up with water.7

We have sampled it and analyzed8the water and assessed whether or not there would9be a risk to the public or the environment. From10our findings we find that there was no stream out11of that pond. It filled up with water to a point12and then it sort of stayed at this particular13level with evaporation and some precipitation.14

We assessed the area around it.15We could find no streams coming out of it.16Therefore, from a human perspective we didn't see17that it was going to affect the downstream18environment.19

MR. JARRELL: If I could just add.20The part I was alluding to was the fact that I21think it was a good example of taking sort of a22risk assessment approach, looking at the water23quality and making decisions as to whether enough24was enough. I think we reached a good25

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harmonious -- we reached an accord with the1regulatory agencies going forward to just2basically leave it as a flooded pond because of3its size and just the risk to the environment.4

MEMBER BARNES: In the case of a5couple of examples, obviously AN-5 and TL-7, where6the radium-226 still continue to be above the COO7levels, right, and station TL-7 is a tailings8creek at Meadow Dam, and in the last few years9there has been -- the trend since about 1982 has10been increasing and sort have been increasing11since 1999, how could you predict at this stage12what sort of a steady state would be over that?13

At the bottom of that page you14indicate that it will perhaps go on for as long as15200 years, so you are giving us a time series of1630 years or so. I come back in the context of17Dr. Thompson's comments of giving us assurance18that there is no real threat to the biota, but19these are levels which on the one hand seem to be20increasing.21

MR. JARRELL: John Jarrell, for22the record.23

Let me at this point introduce the24third member of our team. We got our wires25

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crossed a little bit on timing if you will forgive1us. This is Bruce Halbert. He is a principal at2SENES Consultants, the fellow that has done the3bulk of the modelling for us.4

Maybe to put Bruce on the spot,5maybe I would ask him if he could give some6insight into the modelling, because you are quite7correct, we have 20 years of data and we are8making predictions for very long periods of time.9

MR. HALBERT: Bruce Halbert for10the record. My apologies for being late.11

In relation to the prediction of12future water in the Fulton Creek system, there was13a series of research investigations undertaken to14characterize the sediment, both solid15concentrations and poor water concentrations, as16they act as the primary source, if you want, of17flux, of contaminants back into the water column,18including radium-226.19

Then we calibrated the model to20those data and took that forward in predicting21what the quality would be over time. As that22inventory of contaminants, including radium-226,23has a finite inventory sitting within the24sediments and gradually is depleted, it is a very25

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slim layer of the sediments that actually exchange1at the water column in the order of about 52centimetres.3

So our predictions are that the4peak will be reached somewhere in this period5between 2005 to 2010 and we will gradually see a6downward trend after that.7

MEMBER BARNES: You are assuming8there is no further input into the sediments.9

MR. PHILLIPS: We have transport10downstream from the lakes above. All the lakes,11Fookes Lake, Marie Lake and Greer Lake, act as12sources of radium. The control mechanisms are13different between Fookes and Marie and Greer Lake14in that Greer Lake receives the barium-radium-15sulphate precipitate that was carried over from16the treatment system. As John was referring to,17we see in that system, and we have seen it in18Elliott Lake also, where during the period after19shutdown of treatment and we have the improvement20in water quality and particularly a decrease in21sulphate levels, we do have some radium sulphate22being redissolved and releasing radium back into23the water column.24

But again, it is a finite25

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inventory and over time that inventory is depleted1so the driving force is reduced.2

MEMBER BARNES: Again,3Dr. Thompson, I forget the value that was quoted4for radium-226, the so-called safe value for5biota.6

DR. THOMPSON: Patsy Thompson, for7the record.8

Could you clarify your question?9I am not sure we are --10

MEMBER BARNES: I think you were11asked before what was the safe levels for various12contaminants including radium-226 in drinking13water. You went on to indicate that you didn't14think there was any threat to our poor friendly15invertebrates and so on.16

DR. THOMPSON: Essentially, what17we have done is we have looked at the18concentrations of metals and radionuclides in the19waste areas as well as concentrations in20Beaverlodge Lake. For the radium, we have21actually calculated radiation doses to biota to22assess the risks. It is on that basis that we23have determined that the risks at current radium24levels are minimal and at this time the risks to25

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Beaverlodge Lake are even smaller.1The issue is in terms of2

understanding what will happen in the long term3and verifying that the risks within the site can4be managed to current low levels and decrease with5time while ensuring that the risk to Beaverlodge6Lake do not increase over time. That is the issue7we are grappling with and will be discussed8further with the licensees and other regulatory9agencies.10

THE CHAIRPERSON: I believe,11Dr. Barnes, it was actually the licensee who gave12the Saskatchewan standards. Is that what you were13interested in?14

Could you just repeat,15Mr. Phillips, the standard?16

MR. PHILLIPS: Bob Phillips here,17for the record.18

With regards to water, the19Saskatchewan surface water quality objective for20radium is 0.11 milligrams per litre. That is for21water. That is like for your fish and things like22this.23

Now, there is no Saskatchewan24surface water quality objective for uranium at25

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this time.1MR. JARRELL: John Jarrell, for2

the record. Maybe I could attempt to just add a3little bit.4

At the time that the close-up5criteria were established there weren't sediment6guidelines. That was not the issue. The issue7was, as you would expect from that era, the prime8interest was on water quality. That is what the9objectives were set at, not necessarily the10current investigations, which are sort of11biological effects and sediments and so on and so12forth. That sort of post-dates the establishment13of these criteria.14

While we are on the topic, though,15I thought back -- I am surprised I forgot this, I16was asked what lessons learned. One of the other17lessons that I think is very important is that18digging up contaminated sediments isn't19necessarily the best fix. I think this mine water20lake that we have is a good example. I am in21favour of saying that it still hasn't recovered22from its fix 20 years ago.23

I think the case could be made24that sometimes leaving sediments where they are25

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and perhaps assisting the burial or sort of the1sequestering of some of this contamination is2sometimes as good a solution as is digging them3up. That is certainly a lesson I think we have4learned at Beaverlodge as well.5

MEMBER BARNES: Let me try again,6Dr. Thompson.7

I am looking at, as an example,8figure 3.3.15, which is on page 15 of the velocity9tables at the back of Cameco's document, page 15,10which shows the radium at TL-7. That is one I was11referring to. Do you see the overall trend over12certainly the last 20 years or so and continuing,13quite a little steep pick-up since 1999? I was14wondering if those values, which are given in15becquerels per litre are different from what16Mr. Phillips just gave and how that compares as a17safe or unsafe value for biota?18

How you couched it was that you19were concerned about the watershed as a whole and20Beaverlodge Lake as a whole, which of course is21downstream from all of this. I am trying to22ascertain whether there still remains significant23hotspots that might in fact get hotter over a24period of time that is well beyond even the time25

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series that is reported here.1DR. THOMPSON: Patsy Thompson, for2

the record.3The assessment that staff has done4

uses the data reported in Figure 3.3.15 for the5station you are referring to.6

We have also used data in other7areas. The calculations that staff did were for a8radiation dose to a small fish residing in these9environments. The highest doses would be in the10Greer Lake area and would be lower in the other11areas.12

Even at the most exposed location13the doses are within a range that is about a risk14quotient of 1 or below. So essentially the risk15to fish, even at these concentrations, is low.16

MEMBER BARNES: Just maybe a final17question. To Cameco.18

You are asking for a two-year19licence. Right? Then after that you would20anticipate a 10-year licence, eight-year licence21or --22

MR. JARRELL: John Jarrell, for23the record.24

I don't think we have prejudged25

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that. I think the expectation is, or the hope,1when we come before you the next time for a2licence that we would actually be able to take3some of these minor satellite properties and4remove them from the property. That is our5objective.6

Where we would go forth in that I7think would be a forecast of our estimated time8before we could seek release of the Hab and Dubyna9properties, for instance.10

MEMBER BARNES: I got the11impression, though, that in about a decade or so12you would like to hand this over to the province.13Correct? I am interested, since you have gone14from an indefinite term now to a different kind of15licence in which it is now two years so you would16be back pretty soon, so we will even remember this17situation, does that mean you are going to come18back on a sort of two year basis shedding19different components, or is there an easier way of20perhaps awarding a 10-year licence within which21time you limit your responsibilities or22demonstrate -- I am not quite sure how, because it23is new to me, you actually pass this on to the24province.25

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My follow-up question, which I am1going to ask now is, presumably the province is2well aware of your desire in this case. They are3not here today and I didn't know if in Day 2 --4maybe it is too early for them to be involved in5this process as an agency that will be inheriting6this. Maybe it is when you come back in two7years' time.8

Do you have any comment on the9passage into the provincial realm here and how you10would envisage the sort of licensing of your last11decade or so of this?12

MR. JARRELL: John Jarrell, for13the record.14

The strategy we took was to make15it clear what our business plan was and to develop16a 10-year plan to get to that point. Whether it17takes the 10 years, we obviously hope it will.18

As I stated, we hope to start with19the simplest ones first. Take sort of a walk20before you run approach.21

The other observation, having been22a student of this for a while, is that the23licensing process tends to focus the mind. I24think the expectation is that in two years we will25

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be able to come to some agreement with respect to1the minor satellites.2

I think the best approach here,3and I have seen this in sort of the CMD that4supported licensing periods, is to base them on5sort of logical times, and we have laid out sort6of a logical step for this thing. My concern if7we, for example, just went with a 10-year licence8is we obviously want things to happen over that910-year period of time so I would, at this stage,10be most comfortable with establishing licensing11periods that meet these objectives that we have12set for ourselves.13

I promise that the future CMDs14won't be as lengthy as this one. I am hopeful15that we will be able to focus just on specific16issues.17

MEMBER BARNES: I would just echo18an earlier comment from one of the Commissioners.19I think it is very important to the public record20to have had you make this effort, particularly21with Mr. Phillips' own personal recollections22here. This is well documented.23

THE CHAIRPERSON: Yes, I think24knowledge management tends to be a problem,25

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period, in the industry.1I think what Dr. Barnes was2

referring to is our desire not to be sort of a3burden. It is not necessary in terms of risk.4That is why we are clarifying as well.5

I just would like, for the record,6from staff -- we are talking about moving from a7decommissioning licence to a licence to possess,8manage and store nuclear substances on site. What9is exactly the difference between those two?10

MR. SCISSONS: Kevin Scissons.11There is a couple of objectives12

here. One of them is to move from what was our13original transition plan in 2000, May 2000, from14the transition plan, from the AECB into the CNSC's15regulations and licensing, to take this from AECB16licence into a CNSC licence. Though the licence17is basically captured already captured under our18act, this was more specific to bring it into the19CNSC fold.20

In moving that forward, we have21also recognized the decisions and precedents set22for Elliott Lake, because the facilities in the23uranium mines there have already been24decommissioned. They have also moved now to these25

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waste facility operating licences. So similarly,1we are sticking with that approach, and, as the2decommissioning work has been completed here, have3moved this proposal into a waste facility4operating licence.5

THE CHAIRPERSON: I note that you6are going to come back with regards to7decommissioning plans and try your best on Day 28to look at that -- not decommissioning plan,9financial guarantees.10

As part of that, I think it would11just be helpful if the staff -- I know that the12licensees have talked about their relationship13with Eldor, et cetera. I think it's important14that the staff also provide the Commission with a15sense that you have looked at this structure, in16terms of assurances, that this is where the money17is coming from, so we would have the licensee, but18we would also have the staff having some review of19this. Okay?20

MR. SCISSONS: Kevin Scissons.21Yes, I acknowledge that. That22

really was, and if that message wasn't clear in23our presentation, I apologize. But we are doing24that in concert with Cameco, as well, to confirm25

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with Canada Eldor and CDIC about those assurances.1So we are doing that in concert, yes.2

THE CHAIRPERSON: But we would3like that in your CMD.4

MR. SCISSONS: Yes. You have that5commitment, yes.6

THE CHAIRPERSON: The last point7that I would like to make -- I think it's my last8point -- is you talk about the EA and the9assurances under CEAA, et cetera. You could10imagine that the Commission would like to be11doubly certain about this. We have had our issues12before.13

So I just want you to explore the14previous -- the predecessors of CEAA and just make15sure that there is no leftover requirements or16residuals or something that we are going to get17caught in later. So I want to make doubly sure we18don't have that problem, since we have had that19before.20

If you come back with the same21assurances, that's fine. I just want it --22

MR. SCISSONS: Yes, we have23checked, double-checked and we will check once24more. I hear you, so we will confirm that, yes.25

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THE CHAIRPERSON: Well, maybe you1can provide some more narrative just to support2that, checking back for it.3

MR. SCISSONS: Yes, okay. Staff4will provide that.5

THE CHAIRPERSON: I understand6they have got the Joint Regulatory Group. In7other licences in Saskatchewan we have talked8about how the staff were working with Saskatchewan9Environment on sort of inspections, so that10there's less duplication of inspections.11

Is that happening through the12Joint Regulatory Group? Or can you assure the13Commission that we are using the principles that14we had in other licences in this one still?15

MR. SCISSONS: It's Kevin16Scissons.17

In this particular licence,18because of the status of the project, there really19is only one inspection a year, and it is done by20the Joint Regulatory Group, which, of course, Sask21Environment is part of. It provides us the22opportunity once a year for our staff to be on23site and verify, discuss. We also take the24opportunities at public discussions. We have EQC25

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members attending with us.1So we use that as a very good2

opportunity to touch base on a number of fronts3with a number of agencies and walk the field of4the facility.5

Where necessary, though, Sask6Environment is in the area and doing other checks,7they do that on behalf, on behalf of the group,8and report back to us. So we look for those9efficiencies and opportunities, but, basically,10CNSC staff is there once a year with the other11regulators. That has been our schedule.12

THE CHAIRPERSON: Yes?13MEMBER DOSMAN: So I take it that14

the decommissioning licence embodies active steps15at remediation and a licence to manage substances16involves observation as opposed to remediation.17Am I right on making that distinction?18

MR. SCISSONS: Kevin Scissons.19Not necessarily. To possess and20

manage means maintenance and manage and take21whatever actions may be necessary for the nuclear22substance contained on that facility. If that23required them to do some additional cover work or24maintenance on the tailings areas or additional25

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monitoring or something, it is different.1But you were right initially, in2

the sense that the decommissioning licence was for3the act of decommissioning, major activities to4put the property to rest, do the major remedial5actions, we are now basically in the care and6maintenance and monitoring mode.7

We don't envision there is any8major activities. In the event something does9arise or other actions are evaluated, we would10also assess the appropriate licence that may be11required if a major undertaking or accessible12activity would be required at this same facility.13That is currently not envisioned in the plan.14

MEMBER DOSMAN: Thank you for that15point of clarification.16

THE CHAIRPERSON: Well, thank you17very much, the hearing -- sorry, Mr. Jarrell.18

MR. JARRELL: Sorry, one last19thing we forgot to put in our CMD. There was one20minor request we had for a consideration of a21change in the licence for Day 2 and that's the22timing for the annual report requirement.23

The licence, as it currently is24drafted, suggests that we would provide an annual25

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report in April, which is sort of the standard1fare for this. When this project started 20 years2ago, we agreed on a July-to-a-July campaign or3sampling period, with the September report on an4annual report.5

So it's a relatively minor thing,6but I think that a lot of work could be done to7try to change the database into calendar year. So8it's one area we hope to discuss with the staff is9perhaps a minor modification to the licence.10

THE CHAIRPERSON: Thank you.11Thank you very much, and the staff will consider12that and make recommendations on Day 2.13

This hearing will continue on14November 17, 2004, here in CNSC's office. The15public is invited to participate, either by oral16presentation or written submission on hearing Day172. Persons who wish to intervene on that day must18file submissions by October 18th, 2004.19

This hearing is now adjourned to20November 17th.21